2/16/12 - CONSENT AGMT ISSUED, ASSESSING A PENALTY OF $18,620 DUE WITHIN 30 DAYS.
ON FEB 25, 2010, AN INSPECTION (CEI) WAS CONDUCTED BY EPA AND TDEC. ON AUG 23, 2010, EPA SUBMITTED AN INFO REQUEST LETTER (IRL) TO RESPONDENT IN ORDER TO OBTAIN ADD'L INFO ABOUT RESPONDENT'S CONDUCT OF ITS HAZ WASTE MGMT PROGRAM.
DURING THE CEI:
RESPONDENT INFORMED EPA'S INSPECTOR THAT NUMEROUS PHARMACEUTICAL PRODUCTS TYPICALLY INCLUDED IN THE FACILITY'S FORMULARY COULD BE CLASSIFIED AS HAZ WASTE UPON DISPOSAL BUT, AS OF THE DATE OF THE CEI, THE FACILITY DID NOT MANAGE SUCH WASTE AS HAZ WASTE.
THE EPA INSPECTOR WAS INFORMED BY RESPONDENT THAT PHARMACEUTICAL COMPOUNDS INVENTORIED AT THE FAICLITY INCLUDED SEVERAL ITEMS WHICH, WHEN DISCARGED, WOULD CONSTITUTE AN ACUTE P OR U LISTED HAZ WASTE.
RESPONDENT INFORMED THE INSPECTOR AND SUBSEQUENTLY EXPLAINED IN ITS IRL RESPONSE THAT RESPONDENT'S TYPICAL METHOS FOR DISPOSAL OF PHARMECEUTICAL HAZ WASTE INVOLVED EITHER INCLUDING SUCH WASTES WITH ITS DISPOSAL OF MEDICAL WASTES OR ITS DISPOSAL OF NON-HAZ SOLID WASTE, OR BY DISCHARGE IT TO THE SANITARY SEWER.
THE EPA INSPECTOR OBSERVED A SMALL IN THE 90-DAY HAZ WASTE STORAGE AREA CONTAINING 14 SMALL, CLOSED BOTTLES OF LAB WASTE.
THE EPA INSPECTOR WAS INFORMED THAT RESPONDENT NEITHER KNEW THE SOURCE OF THE BOTTLES OF LAB WASTE, NOR WHETHER ANY OF HTE BOTTLES CONTAINED A HAZ WASTE. HOWEVER, IN ITS RESPONSE TO EPA'S IRL, RESPONDEN4T ACKNOWLEDGED THAT THESE BOTTLES OF LAB WASTE CONTAINED