Claims i. Notification Requirements
The allegations in Paragraphs 1-31 are realleged and incorporated herein by reference.
2. Pursuant to Section 3010(a) of RCRA, 42 U.S.C. ? 6930(a), any person generating a characteristic or listed hazardous waste shall file with the Administrator or authorized State a notification stating the location and general description of such activity and the identified characteristic or listed hazardous wastes handled by such person. No identified characteristic or listed hazardous waste subject to this subchapter may be transported, treated, stored, or disposed of unless notification has been given as required by Section 3010(a) of RCRA, 42 U.S.C. ? 6930(a).
3. Oncor Electric Delivery LLC 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 July 2021, in violation of Section 3010(a) of RCRA, 42 U.S.C. ? 6930(a).
4. 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).
Claims ii. Failure to Operate within Its Stated Generator Status
5. The allegations in Paragraphs 1-31 are realleged and incorporated herein by reference.
6. During the Investigation, EPA determined that Oncor Electric Delivery LLC either operated as a Conditionally Exempt Small Quantity Generator (?CESQG?) and/or c