JULY 16, 2024 - CONSENT AGREEMENT
On February 23, 2023, the Respondent notified TDEC as a LQG of hazardous waste. Since that time, the Respondent has maintained its LQG status.
On September 12-13, 2023, the EPA along with the TDEC, conducted a RCRA Compliance Evaluation Inspection (CEI) at the Facility. The EPA's findings during the CEI were documented in a Report transmitted to the Respondent via email, dated December 14, 2023.
At the time of the CEI, the inspectors observed one 25-gallon container of Chemical Oxygen Demand (COD) test vials (which were identified with the EPA Hazardous Waste Numbers D002, D007, D009, and D0ll) that was not marked with the indication of the hazards of the contents.
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At the time of the CEI, the inspectors observed cracks in both concrete secondary containments around Tank 14 and Tank ET-14.
At the time of the CEI, the Respondent had not determined the average volatile organic concentration of D007 hazardous waste stored in Tank 20 that was generated from the distillation of nitric acid.
The Respondent consents to the payment of a civil penalty, which was calculated in accordance with the Act, in the amount of TWENTY-THOUSAND NINE HUNDRED DOLLARS ($20,900.00), which is to be paid within 30 days of the Effective Date of this CAFO.