OCTOBER 17, 2023 - CONSENT AGREEMENT
On October 28, 2022, the EPA and TDEC conducted a compliance evaluation inspection (CEI) at the Respondent's Facility.
The Respondent was using a solvent mixture containing normal propyl acetate and normal propyl alcohol to perform ongoing cleaning operations on two of the Facility's printing presses. Following the use of the solvent mixture for cleaning of the presses, the solvent mixture became spent.
The spent solvent mixture generated by the cleaning of the two separate presses was accumulated in two individual tank systems which are part of the Facility's two printing presses.
The Respondent had not made a hazardous waste determination on the spent solvent mixture of normal propyl acetate and normal propyl alcohol when it was managed in the Spent Solvent Tanks. Respondent only identified the spent solvent mixture as a hazardous waste exhibiting the characteristic of ignitability once the spent solvent mixture was removed from the Spent Solvent Tanks.
The inspectors observed eight (8) open 55-gallon containers of hazardous waste within SAAs at the Facility in the area of its printing presses.
The inspectors observed two (2) containers of hazardous waste within SAAs at the Facility in the area of its printing presses which were not labeled with the words Hazardous Waste or an indication of the hazards of the contents.
The inspectors observed that the Respondent had not performed weekly inspections of its CAA look