SEPTEMBER 19, 2023 - CONSENT AGREEMENT
On September 14 and 15, 2021, the EPA and KYDEP conducted a RCRA compliance evaluation inspection (CEI) at Respondents Facility. The EPA?s findings of the CEI were documented in a report electronically mailed to Respondent, dated November 10, 2021.
Respondent had notified as a LQG of hazardous waste and a permitted hazardous waste treatment and storage facility.
Respondent accumulates less than 5,000 kilograms of universal waste at any time and is therefore a SQHUW.
The EPA inspectors observed that Respondent had failed to conduct a hazardous waste determination on the following four waste streams generated at the Facility:
The inspectors observed an open 5-gallon hazardous waste container storing waste aerosol cans (D001) in the SAA near the Hydropulper. This container was not marked with the words ?Hazardous Waste,? and was also not marked with an indication of the hazards of the contents.
The inspectors observed a 55-gallon hazardous waste accumulation container that did not appear to be in good condition, with a rusted lid.
The inspectors observed a 55-gallon hazardous waste accumulation container of solvent-contaminated wipes and Tin Recovery System (TRS) personal protective equipment (PPE) that was not closed due to an improperly working drum lid in the Area B-12 CAA outside the Laboratory.
A review of daily inspection logs revealed that Respondent failed to conduct daily inspections of the TK-1709 CAA Tank storing waste