Claim i: Failure to Notify of Generator Category
17. EPA hereby restates and incorporates by reference Paragraphs 1 through 16.
18. 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 EPA or the authorized state a notification stating the location and general description of such activity and the identified characteristic or listed hazardous waste 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).
19. The Louisiana Administrative Code in LAC 33.V.1017.A requires generators to notify the Louisiana Office of Environmental Services within 7 days if any information submitted in the prior notification of hazardous waste activity changes.
20. Respondent?s notification to the Louisiana Department of Environmental Quality (LDEQ) on August 13, 2015, identified the Facility as a Conditionally Exempt Small Quantity Generator (CESQG).
21. This status was not updated until February 26, 2020, when the Respondent notified LDEQ that it was a Large Quantity Generator (LQG).
22. Hazardous waste manifests from Respondent from June, July, and August of 2018 and January and February of 2020 indicate that, at some point in each of these years, Respondent generated greater than 1,000 kg per month of hazardo