Claim.1 Notification Requirements
22. The allegations in Paragraphs 1-21 are re-alleged and incorporated herein by reference.
23. Pursuant to LAC 33:V. l 105.B, [42 U.S.C. ? 6930(a)], a generator must notify the Office of
Environmental Services within seven days if any of the information submitted in the
application for the identification number changes.
24. As identified in Paragraph 18, Respondent generated hazardous waste above the threshold
amount of a Small Quantity Generator during 2018.
Respondent did not file with EPA or Louisiana Office of Environmental Services an updated
notification of its hazardous waste activities above that of a Small Quantity Generator at the
American Recovery Facility during 2018, in violation of LAC 33:V.l 105.B, (42 U.S.C. ?
6930(a)].
Claim. 2 Failure to Operate within Its Stated Generator Status
26. The allegations in Paragraphs 1-21 are realleged and incorporated herein by reference.
27. Pursuant to LAC 33:V.l 109.E.2. (40 C.F.R. ? ~62.34(b)], any person who generates in
excess of l ,000 kilograms of hazardous waste in any given calendar month is a Large
Quantity Generator of hazardous waste, and is subject to the permitting requirements as
specified in LAC 33:V.Subpart 1.
28. During portions of 2018, the American Recovery Facility exceeded their declared Small
Quantity Generator status and operated in some instances as a Large Quantity Generator in
violation of one or more of the requirements for Large Quantity Generat