AUGUST 19, 2024 - CONSENT AGREEMENT
On April 18, 2023, the EPA and the Georgia Environmental Protection Division (GAEPD) conducted a joint RCRA Compliance Evaluation Inspection (CEI) at the Facility.
At the time of the CEI, the Respondent could not demonstrate it had submitted a QRG of the Contingency Plan to local emergency responders after it had amended its contingency plan in 2021.
On August 8, 2023, the EPA emailed the Respondent an Opportunity to Show Cause Letter anda CEI Report documenting its findings from the CEI.
At the time of the CEI, the Respondent was attempting to identify a recycler to accept the toluene distillate accumulating in Tank T-80.
At the time of the CEI, the Respondent had not made an accurate hazardous waste determination on the toluene distillate in Tank T-80 at the Facility as it believed the material was a HSM.
On May 4, 2023, and June 20, 2023, the Respondent shipped the toluene distillate in Tank T-80, identified with the EPA Hazardous Waste Numbers D001, D035, D038, F003, and FOOS, to Geocycle, LLC and Giant Cement Company for disposal.
At the time of the CEI, inspectors observed a four (4) liter container of D001 laboratory waste in the SAA of the Quality Control (QC) Laboratory. The container had a hose inserted into the lid that prevented the lid from closing.
At the time of the CEI, inspectors observed a sudden or non-sudden spill of F-listed hazardous waste sludge generated from the rotary fan press on the concre