8/13/20 - CONSENT AGREEMENT AND FINAL ORDER - At the time of the June 21, 2019 inspection.Respondent was generating a spent methanol and isopropyl alcohol (IPA) solvent waste mixture as a result of cleaning process tanks used to manufacture calcium and sodium docusates at its facility. The spent methanol and IPA solvent mixture has a flashpoint of less than 140 degrees Fahrenheit and
is a D001 characteristic and F003 listed hazardous waste.Respondent had not determined that the spent methanol and IPA solvent mixture was a D001 characteristic and F003 listed hazardous waste and had not determined whether the waste met the LDR treatment standards. Respondent was sending the spent methanol and IPA solvent mixture off-site without a hazardous waste manifest or a land disposal restriction notice. The spent methanol and IPA solvent waste mixture had been sent off-site without a hazardous waste manifest or accompanying land disposal restriction notice on thirty separate occasions beginning on January 16, 2015. At the time of the August 6, 2019 CEI, a 275 gallon container was observed within an SAA located in the immediate vicinity of the process tanks that were cleaned with methanol between production batches of sodium and calcium docusate. The 275-gallon container was collecting spent methanol and IPA hazardous waste. The container was labeled with the words Hazardous Waste and marked with an accumulation start date of less than three days from the time of the