SEPTEMBER 16, 2021 - CONSENT AGREEMENT AND FINAL ORDER ISSUED: On March 11, 2021, the EPA and MDEQ conducted a RCRA compliance evaluation inspection(CEI) at Respondent?s Facility. At the time of the CEI, the inspectors observed three (3) 5-gallon containers of retain sample hazardous waste (EPA waste codes D001, F003, F005) in the SAA that were not marked with an indication of the hazardous contents. At the time of the CEI, the Respondent had no records to show that the original contingency plan, or any of its revisions, had been provided to local police departments, fire departments,
hospitals, and state and local response teams that may be asked to provide emergency assistance. At the time of the CEI, the inspectors observed cracks and gaps in the external liner system of the secondary containment for the hazardous waste storage and treatment tank systems. At the time of the CEI, the inspectors observed that the Respondent did not calibrate the Tiger photoionization detector (PID), a leak detection device, in accordance with the Subpart BB Test Methods and Procedures for all equipment subject to Subpart BB. At the time of the CEI, the inspectors observed ancillary equipment subject to Subpart BB that was not tagged with a legible unique identification number.