EPA has received and reviewed one year exception reports submitted by Chemical Waste Management of the Northwest on 2/15, 3/2 and 3/7/2006. As a disposal facility, CWMNW was required to submit these reports in accordance with 40 CFR Sec 761.215(c) and (d). Included with the reports are copies of Uniform Hazardous Waste Manifests number 382922, 382918, 382875 and 382873. According to these manifests and other information obtained by EPA, Alaska Gold Company (AGC) was the generator of more than 8,000 kilograms of PCB items which were shipped for disposal to CWMNW on 9/20/2005. The documentation further shows the PCB items were received by CWMNW in the middle of January 2006 and were disposed of by CWMNW almost one month earlier.
The out of service dates for the PCB items were each more than one yea prior to disposal of the items at CWMNW. According to 40 CFR Sec 761.61(a)(a), a generator has one yea from the out of service date of a PCB item to dispose of the item. AGC failed to dispose of the PCB items delineated on the four manifests within one year of the out of service dates for these items, resulting in four violations of 40 CFR Sec 761.65(a)(1).