12/18/2006 complaint issued: Respondent failed to use closure devices of suitable material for openings on hazardous waste Tank #2205 A/B and Tank #2209 A/B in violation of 40 C.F.R. 265.1085(c)(iv). Failure to properly design, construct, maintain, and operate the facility in violation of 40 C.F.R. § 264.31 and Module II-A of the 1988 permit as modified by the 1995 permit modification.
Facility replaced defective flanges and gaskets on stroage tanks.
04/17/2007 amended complaint issued: This is an amended Complaint (4/17/2007) which includes one Count for: 40 C.F.R. § 265.1085(c)(iv); failure to use closure devices of suitable material for openings on hazardous waste Tank #2205 A/B and Tank #2209 A/B in violation of 40 C.F.R. 265.1085(c)(iv). This Complaint was amended by removing one Count from the original Complaint citing a violation of: 40 C.F.R. § 264.31; failure to properly design, construct, maintain, and operate the facility in violation of 40 C.F.R. § 264.31 and Module II-A of the 1988 permit as modified by the 1995 permit modification. This amended Complaint reduces the original proposed penalty from $32,500 to $10,399 in the amended form.