FAILURE TO MAKE A HAZ-WASTE DETERMINATION AND TO PREPARE A MANIFEST. OFFERED HAZ-WASTE TO TRANSPORTER AND TSDF THAT DID NOT HAVE AN EPA ID NUMBER; AND FAILURE TO OBTAIN A RCRA PERMIT.
CCDS: The facility was inspected on September 20, 2000. The following violations were found: 6 NYCRR Part 372.2(a)(2), failure to make a hazardous waste determination for lead-contaminated wastes from one of their processes; 6 NYCRR Parts 372.(b)(1) and 372.2(b)(5)(i), shipping this hazardous waste without a manifest; 6 NYCRR part 372.2(a)(3)(ii), utilizing a transporter that has not received an EPA ID number to transport this hazardous waste; and 42 U.S.C. 6925 and 6 NYCRR Part 373-1.2, failure to obtain a RCRA permit. It was determined that the facility shipped approximately 10 tons of D008 hazardous waste to a landfill during a 2-year period prior to the inspection.