SEPTEMBER 9, 2024 - CONSENT AGREEMENT
On May 04, 2023, the EPA and KYDEP conducted a RCRA compliance evaluation inspection {CEI) )at the Respondent's Facility. The EPA's findings of the CEI were documented in a report electronically mailed to the Respondent on September 26, 2023.
The inspectors observed multiple containers of Lead Azide (D002, D008}} hazardous waste with locking rings in the open position and not securely closed in the Multi-Reaction Facility (MRF} 3 CAA.
The Respondent failed to provide a weekly inspection record of the Facility's CAAs for the last week of December 2022. It was later determined that weekly inspections were not conducted during the last week of December 2022.
The inspectors reviewed daily tank inspection records and observed that the Respondent failed to conduct over 90 daily tank inspections for hazardous waste tank TKS03 and over 100 daily tank inspections for hazardous waste tank TK3000 in 2022.
The inspectors found that the Respondent had failed to determine the organic concentration of the hazardous waste contained in or in contact with each piece of equipment in the hazardous waste tank system, to determine whether the equipment contains or contacts hazardous waste with an organic concentration of at least 10 percent by weight in accordance with the Air Emission Standards for Equipment Leaks.
The inspectors found that the Respondent had failed to determine the average volatile organic (VO} concentration of hazardous w