On June 26, 2023, EPA Region 6 issued a Consent Agreement and Final Order (CAFO) under its authority pursuant to the Resource Conservation and Recovery Act (RCRA) to Opelousas General Health Systems located in Opelousas, LA. The CAFO was issued in response to violations of:
i. Failure to file an adequate or accurate initial or subsequent notification;
ii. Failure to meet the requirements of a Small Quantity Generator; and
iii. Failure to meet hazardous waste treatment requirements.
The CAFO requires Opelousas to:
A. Respondent shall certify that it has assessed all its solid waste streams at the Opelousas General Facility to determine the accurate waste codes and has developed and implemented standard operating procedures ( SOPs ) to ensure that Respondent is operating the Opelousas General Facility in compliance with RCRA and the regulations promulgated thereunder that have been alleged to have been violated in this matter, specifically, procedures for: (a) making hazardous waste determinations; (b) managing hazardous wastes; (c) reporting, transporting, and disposing of hazardous waste; (d) preparing its manifests; and (e) meeting the requirements of the land disposal restrictions;
B. Respondent shall certify that it has accurately and adequately complied with its RCRA Section 3010 notification for the Opelousas General Facility as of the date of certification; and
C. Respondent shall provide, with its certification, a description of Respondent?s SOPs as descri