SEPTEMBER 11, 2025 - CONSENT AGREEMENT
On March 6, 2024, the EPA and TDEC conducted a hazardous waste compliance evaluation inspection (CEI) at the Facility. The EPA's findings of the CEI were documented in a Report that was emailed to Respondent on June 11, 2024.
The inspectors observed that Respondent had not made an accurate hazardous waste determination on the following:
a. spent aerosol cans in the Raw Material Warehouse;
b. one 55-gallon container affixed with a vacuum to accumulate the dust in the Assembly Area;
c. eight 55-gallon unmarked containers storing unknown material on the south side of the building.
The inspectors observed three open 55-gallon containers of lead? contaminated Personal Protective Equipment (PPE) hazardous waste in three SAAs around the Facility:
The inspectors observed five SAA containers of hazardous waste PPE (D008) that were not marked with the words Hazardous Waste or with an indication of the hazards of their contents. These containers were found in four SAAs around the Facility.
The inspectors observed two 55-gallon containers for accumulating hazardous waste PPE in the Wastewater Treatment Area SAA. One of the containers was completely full of hazardous waste, and the other was partially full of hazardous waste.
Therefore, the total volume of hazardous waste observed in the SAA exceeded 55 gallons.
The inspectors observed hazardous waste contaminated PPE outside of a container on a pallet beside the Wastewater