8/31/2011 - NOTICE OF DETERMINATION ISSUED. IN A SELF-DISCLOSURE DAGTED APRIL 17, 2009, ANDERSON UNIVERSITY DISCLOSED VIOLATION OF THE CAA, CWA, FIFRA, AND RCRA. ANDERSON UNIVERSITY CORRECTED ALL VIOLATIONS BY MAY 31, 2009.
THE SELF-DISCLOSURE ALSO INCLUDED POTENTIONS OF THE CAA'S NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR ASBESTOS; THE REPORTING PROVISIONS OF EPCRA, AND THE PCB MAINTENANCE AND INVENTORY REQUIREMENTS OF TSCA. HOWEVER, EPA DETERMINED THAT THESE DISCLOSURES DID NOT CONSTITUTE VIOLATIONS OF FEDERAL LAW, AND THEREFORE, THEY WERE NOT REVIEWED UNDER THE AUDIT POLICY.
VIOLATIONS:
CAA:
- NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANT FOR CONTAINERS; FAILURE TO MAINTAIN PROPER CLOSURES ON CHEMICAL CONTAINERS.
CWA/SPCC:
- UNAUTHORIZED DISCHARGE OF POLLUTANTS TO POTW.
- CHEMICAL CONTAINERS STORED ABOVE SINK WITHOUT A SECONDARY CONTAINMENT.
- FAILURE TO INSTALL SEDIMENT TRAPS TO CAPTURE CLAYS, ROCK DEBRIS AND SEDIMENT.
- FUME HOODS WITH UNPROTECTED CUP HOODS AND FAILURE TO STORE HAZARDOUS MATERIALS IN SECONDARY CONTAINMENT.
- FAILURE TO DEVELOP AND IMPLEMENT SPCC PLAN FOR FACILITY THAT POSSESSES GRATER THAN 1,320 GALLONS OF ABOVE-GROUND OIL STORAGE.
- FAILURE TO PROVIDE SECONDARY CONTAINMENT FOR OIL CONTAINING VESSELS 55-GALLONS OR LARGER.
- FAILURE TO TRAIN PERSONNEL IN SPCC PLAN REQUIREMENTS.
- FAILURE TO CONDUCT INSPECTIONS OF AND MAINTAIN RECORDS FOR OIL CONTAINING VESSELS.
- FAILURE TO PROPERLY MANAGE WASTE COOKING OIL.