9/2/11 - CONSENT AGMT ISSUED, ASSESSING PENALTY OF $10,000 DUE W/IN 30 DAYS.
ALLEGATIONS:
ON DEC 7, 2010, EPA PERFORMED A RCRA CEI.
AT TIME OF THE DEC 7, 2010 CEI, RESPONDENT HAD NOT MADE HAZ WASTE DETERMINATIONS ON CERTAIN SOLID WASTES GENERATED INCLUDING THE SPENT SOLVENT, SPENT ALCOHOL AND OTHER CHEMICAL WASTE STREAMS GENERATED IN THE ENFD LAB, THE SPENT PAPER TOWELS AND WASTEWATER GENERATED IN THE MICROBIOLOGY LAB, THE SPENT BLOCK PADS AND COTTON SWABS GENERATED IN THE MICROBIOLOGY LAB AND ABSORBENT PADS USED TO RESPOND TO A SPILL OF HAZ WASTE ON THE FLOOR OF THE LESS THAN 180-DAY CENTRAL HAZ WASTE ACCUMULATION AREA. EPA ALLEGES RESPONDENT VIOLATED GA COMP R AND REGS 391-3-11-.08(1) (40 CFR 262.11) BY FAILING TO MAKE A HAZ WASTE DETERMINATION ON SOLID WASTE GENERATED.
EPA REVIEWED THE FACILITY'S HAZ WASTE MANIFESTS AND OBSERVED THAT FROM DEC 2009 TO TIME OF CEI, FACILITY GENERATED GREATER THAN 100 KG BUT LESS THAN 1000 KG OF HAZ WASTE EACH CALENDAR MONTH, MAKING IT AN SQG. HOWEVER, FACILITY FAILED TO NOTIFY THE STATE OF ITS ACTIVITY AS A HAZ WASTE GENERATOR AND OBTAIN AN EPA ID NUMBER UNTIL APR 19, 2010. EPA ALLEGES RESPONDENT VIOLATED GA COMP R AND REGS 391-3-11-.08(1) (40 CFR 262.12(a) BY FAILING TO OBTAIN AN EPA ID NUMBER FROM THE STATE PRIOR TO TREATING, STORING, DISPOSING OF TRANSPORTING OR OFFERING FOR TRANSPORTATION HAZ WASTE.
EPA OBSERVED THAT THE FACILITY DID NOT PREPARE A MANIFEST ON EPA FORM 8700-22 PRIOR TO OFFERING FOR TRANSPORT A HAZ WASTE FO