AUGUST 29, 2022 - CONSENT AGREEMENT
On February 27, 2020, the Respondent notified the Georgia Environmental Protection Division (GAEPD) of its status as a large quantity generator of hazardous waste. In this notification, the Respondent identified the generation of hazardous wastes. Respondent has maintained its LQG status at all times relevant to this CAFO.
On January 22, 2021, the EPA contacted Respondent to inform it of the EPA's intent to complete a RCRA Virtual Evaluation (VE) and requested Respondent to provide a list of information and documentation necessary to complete the VE.
On February 18, 2021, and March 5, 2021, the EPA received additional information from Respondent as part of its response to the VE.
At the time of the VE, the inspectors were informed, and subsequent information confirmed that Tank 2053 was used to store C74, a material made with still bottoms and spent solvent. The unsold C74 was identified with EPA hazardous waste codes D00 I, F003, and FOOS. Respondent stored C74 in Tank 2053 for over three years prior to shipping it off-site without determining that the stored
material was a solid or hazardous waste, complying with the hazardous waste storage requirements, or obtaining a permit.
At the time of the VE, the inspectors observed that the Respondent failed to maintain tight-fitting or sealed lids that remain closed on the following containers holding hazardous waste.