AUGUST 2, 2022 - CONSENT AGREEMENT: On August 30-31, 2021, EPA and TDEC conducted a compliance evaluation inspection (CEI) at the Respondent's Facility. EPA's findings of the CEI were documented in a report initially emailed to the Respondent on October 21, 2021, and the amended report dated November 22, 2021.
At the time of the inspection, the EPA inspector observed that the Respondent failed to clearly mark an accumulation start date and failed to label or clearly mark the words Hazardous Waste on two containers of spent solvent from glue gun cleaning activities (F003/F005), conducted in the spray booths, (F003/F005) and one container of MDI spent solvent (D001 /0035), conducted in the
Glass Mat Room, both in the Central Accumulation Area (CAA) in the Glue Room; and that Respondent failed to clearly mark the accumulation stai1 date on one container of glue contaminated solvent (F003/F005) and failed to label or clearly mark the words Hazardous Waste on one container of still bottoms (F003/F005), both in the Glue Room Recycle Area CAA. EPA inspector reviewed records that indicated the glue gun operators, which generate and manage spent solvent from glue gun flushing, and the Glue Room operators, which generate and manage used oil, universal waste, and hazardous waste in CAAs, did not receive an annual RCRA refresher training in 2020. EPA inspector reviewed training records for personnel that generate and manage spent solvent from glue gun flushing activities (F003/F