SEPTEMBER 16, 2024 - CONSENT AGREEMENT
On March 14, 2023, the EPA conducted a compliance evaluation inspection (CEI) at the Respondent's Facility. The EPA's findings of the CEI were documented in a Report emailed to the Respondent on May 10, 2023.
EPA observed that the Respondent had failed to make an accurate hazardous waste determination for the acetone contaminated wastewater accumulating in the secondary containment area. During the CEI, the inspectors observed a pump leaking acetone into the secondary containment area and brought the need for an accurate hazardous waste determination to the attention of Facility personnel. On March 24, 2023, the Respondent shipped off the wastewater from the secondary containment area as nonhazardous waste. The Respondent did not provide a hazardous waste determination for the wastewater as generated at the time of the CEI.
EPA observed an improperly sealed 55-gallon container of hazardous waste spent filters labeled as ?Hazardous Waste,? but without identifying the hazards of the container?s contents, in the SAA in the Production Room.
EPA requested the records for the previous three years of weekly inspections of the hazardous waste CAA. The Respondent was only able to demonstrate it had conducted weekly inspections during November 2022 and December 2022.
EPA observed that the Respondent was not applying the requirements of the RCRA Hazardous Waste Tank Standards or the Organic Air Emission Standards for managing hazardou