California Technical Plating CA/FO

On October 28, 2010, U.S. Environmental Protection Agency (EPA) representatives conducted an unannounced site inspection of CTP, located in San Fernando, California. The purpose of the inspection was to determine CTP’s compliance with applicable federal environmental statutes and regulations, and in particular, the Resource Conservation and Recovery Act (RCRA), as amended, the regulations provided in the Code of Federal Regulations (CFR), Chapter 40, Parts 261-265, 268, and 279, and the California Code Regulations (CCR), Title 22, Division 4.5 and the California Health and Safety Code, Division 20. CTP provides 17 plating processes to their customers, which are primarily in the aerospace industry. CTP is an FAA repair station and they plate jet engine components. Their focus is on small components, ranging from half inch to three feet in length. CTP is also a job shop and provides painting and coating services. , EPA alleges that Cal Tech Plating committed the following violations of the authorized State’s RCRA regulatory requirements: • Storage of hazardous waste without a permit in violation of 22 C.C.R. § 66270.1 (see also 40 C.F.R. § 270.1); • Failure to close containers of hazardous waste in violation of 22 C.C.R. § 66265.173(a) (see also 40 C.F.R. § 265.173(a), 22 C.C.R. § 66273.33(b)(1) and 40 C.F.R. § 273.13(d)(1)); • Failure to maintain adequate aisle space in hazardous waste storage area in violation of 22 C.C.R. § 66265.35 (see also