Notification Requirements. Blue Cross Blue Shield of Louisiana did not file with the Administrator an initial or subsequent notification to accurately state the general description of its hazardous waste activities and its generation and management of hazardous waste during 2015, 2018, 2019 and 2020, in violation of Section 3010(a) of RCRA, 42 U.S.C. ? 6930(a). At all times relevant to this ACOC, Respondent failed to comply with its notification requirements in violation of Section 3010(a) of RCRA, 42 U.S.C. ? 6930(a).
Failure to Operate within its Stated Generator Status. On more than one occasion in 2015, 2018, 2019 and 2020, Blue Cross Blue Shield of Louisiana exceeded the CESQG status and, for the period such hazardous waste remained onsite, operated as a SQG in violation of one or more of the requirements for SQG under 30 LAC 33:V.1109.E, [40 C.F.R. ? 262.34].