3/1/18 - CONSENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $7,000 DUE WITHIN 30 DAYS.
ALLEGATIONS:
ON JAN 4, 2017, EPA CONDUCTED A COMPLIANCE EVALUATION INSPECTION (CEI) AT RESPONDENT'S FACILITY.
DURING THE CEI, EPA OBSERVED:
- RESPONDENT FAILED TO DOCUMENT INSPECTIONS OF CONTAINERS OF HAZ WASTE ACCUMULATING ON-SITE FROM FEB 18, 2016 TO JUNE 24, 2016. EPA ALLEGES THAT RESPONDENT VIOLATED SEC 12-8-66 OF THE GHWMA, GA. CODE ANN 12-8-66 (RCRA 3005) BY STORING HAZ WASTE W/OUT A PERMIT OR INTERIM STATUS, BECAUSE RESPONDENT FAILED TO MEET A CONDITION OF THE SQG PERMIT EXEMPTION SET FORTH IN GA. COMP. R. AND REGS 391-3-11-0.08(1) (40 CFR 262.34(d)(2)) BY NOT COMPLYING WITH THE DOCUMENTATION OF INSPECTIONS OF REQUIREMENT OF GA COMP. R. AND REGS 391-3-11-.10(1).
- RESPONDENT HAD ONE 4-FT CARDBOARD BOX CONTAINING FLUORESCENT TUBES WHICH WAS UNLABELED AND OPEN AT THE TIME OF THE INSPECTION. EPA ALLEGES RESPONDENT VIOLATED GA COMP R. AND REGS 391-3-11.18 (40 CFR 273.13(d), BY FAILING TO MANAGE SPENT UNIVERSAL WASTE LAMPS IN A WAY THAT PREVENTS RELEASES OF ANY UNIVERSAL WASTE OR COMPONENT OF A UNIVERSAL WASTE TO THE ENVIRONMENT. EPA ALLEGES RESPONDENT VIOLATED GA COMP R AND REGS 391-3-11-.18 (40 CFR 273.14(e)) BY FAILING TO LABEL OR MARK EACH LAMP OR CONTAINER OF LAMPS CLEARLY WITH ONE OF THE FOLLOWING PHRASES UNIVERSAL WASTE-LAMP(S) OR WASTE LAMPS OR USED LAMPS .
- EPA DETERMINED THAT RESPONDENT FAILED TO PREPARE ITS HAZ WASTE MANIFESTS ON EPA FORM 8700-22 ACCORDING