8/27/13 - CONSENT AGMT ISSUED, ASSESSING A PENALTY OF $39,600, DUE WITHIN 30 DAYS.
ALLEGATIONS:
RESPONDENT IS A STATE UNIVERSITY WITH A MEDICAL CENTER AND SIX COLLEGES FOR THE EDUCATION OF A BROAD RANGE OF HEALTH PROFESSIONALS, BIOMEDICAL SCIENTISTS, AND OTHER HEALTH RELATED PERSONNEL.
RESPONDENT GENERATES HAZARDOUS WASTE AS A RESULT OF LABORATORY OPERATIONS AND FACILITY MAINTENANCE. RESONDENT IS A LQG OF HAZ WASTE.
ON MAY 1, 2012, INSPECTORS FROM EPA AND THE SCDHEC CONDUCTED A RCRA COMPLIANCE EVALUATION INSPECTION (CEI) OF RHE RESPONDENT'S FACILITY. AT THAT TIME, SEVERAL VIOLATIONS OF RCRA WERE OBSERVED. WITHIN A WEEK OF THE CEI, RESPONDENT CORRECTED ALL OF THE VIOLATIONS. THE FINDINGS OF THE CEI WERE DOCUMENTED IN THE EPA RCRA CEI REPORT, DATED NOV 6, 2012, AND SCDHEC CEI REPORT, DATED DEC 11, 2012.
DURING THE CEI, THE INSPECTORS OBSERVED THE RESPONDENT FAILED TO CONDUCT WASTE DETERMINATIONS ON THE FOLLOWING SOLID WASTES, WHICH WERE LATER DETERMINED TO BE HAZARDOUS WASTES:
- THE CONTENTS OF ONE 4-LITER CONTAINER CONNECTED TO A HIGH PERFORMANCE LIQUID CHROMATOGRAPH (HPLC) MACHINE LOCATED IN THE NEW DRUG DISCOVERY BLDG LAB ROOM #421. ON MAY 3, 2012, RESPONDENT PROVIDED EPA WITH DOCUMENTATION THAT THIS WASTE WAS DETERMINED TO BE A 50/50 MIXTURE OF WASTE AND METHANOL AND WATER.
- THE CONTENTS OF ONE 1-GAL CONTAINER LOCATED IN THE NEW DRUG DISCOVERY BLDG LAB ROOM #422. ON MAY 3, 2012, RESPONDENT PROVIDED EPA WIHT DOCUMENTATION THAT THIS WASTE WAS A MIXTURE