OCTOBER 29, 2025 - CONSENT AGREEMENT
On April 9, 2024, EPA inspectors, accompanied by inspectors for the SCDES, conducted an unannounced RCRA compliance evaluation inspection (CEI) at the Facility. The EPA?s results of this CEI were provided to the Respondent in a report dated July 2, 2024.
The inspectors observed one 4-liter amber jar for spent high performance liquid chromatography (HPLC) which held 100 milliliters (mL) of liquid in the
SAA of the Facility's Laboratory. The container was open, and the inspectors observed tubing from an idle HPLC machine in the container opening. No hazardous waste was being added to or removed from the open container.
The inspectors observed one container of spent lead acid batteries and one container holding a single spent lithium battery. The containers were not labeled with the words ?Universal Waste ? Battery(ies),? ?Waste ? Battery(ies),? or ?Used Battery(ies).?
The Respondent was not able to demonstrate the length of time that universal waste had been accumulated from the date it became a waste or was received.
The inspectors observed hazardous waste leaking from a recirculation pump onto the secondary containment of the permitted hazardous waste storage tank - the West Organic
The inspectors observed an area of corroded concrete that needed repair under the sample port in the permitted secondary containment system.
The inspectors reviewed the Facility?s most recent Hazardous Waste Generator Notification (EPA Form 8700-12),