The City of Tacoma (Tacoma) currently accepts household hazardous waste (including used oil) at their City of Tacoma Household Hazardous Waste Facility (Tacoma Landfill). On May 8, 2012 Tacoma shipped 750 gallons of PCB contaminated oil contributing to the contamination of approximately 8,250 gallons of used oil at Emerald Services, Inc. (Emerald); an oil recycling and reuse facility in Seattle. The used oil was not marked or manifested and the City was unaware that it contained PCBs.
EPA became aware of the violations via a May 25, 2012 Unmanifested Waste Report provided by Emerald Services (required by 40 CFR 761.211). The Report indicated that Emerald conducted oil sampling (using their internal lab) on May 9, 2012 as part of routine PCB testing and discovered PCBÂs potentially above 50 ppm (i.e., TSCA regulated threshold). Emerald traced the PCB contamination to Tacoma using screening truck retain samples. Third party laboratory analysis (received May 15, 2012) confirmed PCB concentrations greater than 50 ppm in the used oil provided by Tacoma. Emerald disposed of the oil June 5-7, 2012 via Clear Harbors.
TacomaÂs violations include: 1) Failure to notify EPA in advance of the shipment of this PCB-contaminated used oil, or obtain an EPA identification number, 2) failure to prepare a manifest on ÂEPA Form 8700-22Â for the shipment of PCB-contaminated used oil, and 3) Placing the product into commerce by offering the contaminated used oil for transport and reu