On March 3, 2020, Region 5 executed an Expedited Settlement Agreement (ESA) with Atlas Chem Milling (Respondent) regarding its facility located in Elkhart, Indiana (the Facility). At the Facility, Respondent manufactures custom-made cutting dies and the Facility operates as a large quantity generator. The Facility generates various types of hazardous waste; including, ferric chloride hazardous waste, F006 hazardous waste from the waste water treatment unit, flammable paint, solvent contaminated wipes, used oil and universal waste.
On September 13, 2018, EPA conducted a compliance inspection at the Facility and determined that Respondent unlawfully stored hazardous waste without a permit or interim status as a result of its failure to comply with certain conditions for a permit exception under 329 Ind. Admin. Code 3.1-7-1. [40 C.F.R. ? 262.34(a)-(c)]. Specifically, EPA found that Respondent: (a) failed to mark one cubic yard container of F006 waste with the date of accumulation; (b) failed to conduct weekly inspections of the hazardous waste storage areas; (c) failed to conduct an annual review of the initial training required; (d) failed to conduct daily documented inspections of the hazardous waste storage tank and failed to inspect data gathered from the monitoring and leak detection equipment on a daily basis; (e) failed to submit an exception report to the EPA Regional Administrator; and, (f) failed to demonstrate the length of time that the universal waste had been ac