EPA v. CEDAR CREST COLLEGE

Case summary

Self disclsure of the following violaitons: Violation 1: Prior to June 7, 2004, maintenance records for a refrigeration unit containing more than 50 pounds of refrigerant did not include leak rate calculations, in violation of 40 C.F.R. �� 82.166(k). Violation 2: Prior to June 29, 2004, Cedar Crest College, a small quantity generator as that term is used by 40 C.F.R. �� 260.10, failed to ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies, in violation of 40 C.F.R. �� 262.34(d)(5)(iii). Violation 3: Prior to July 14, 2004, Cedar Crest College, a small quantity generator as that term is used by 40 C.F.R. �� 260.10, failed to conduct periodic inspections of its waste accumulation area, in violation of 40 C.F.R. �� 262.34(d)(2), which is incorporated by reference in the authorized Pennsylvania Hazardous Waste Program, 25 Pa. Code Ch. 262. Violation 4: Prior to June 22, 2004, Cedar Crest College, a small quantity generator as that term is used by 40 C.F.R. �� 260.10, failed to mark containers used to accumulate hazardous waste with the accumulation start date, in violation of 40 C.F.R. �� 262.34(a)(2).which is incorporated by reference in the authorized Pennsylvania Hazardous Waste Program, 25 Pa. Code Ch. 262. Violation 5: Prior to July 9, 2004, Cedar Crest College, a small quantity generator as that term is used by 40 C.F.R. �� 260.10, failed to ensure that containers used to contain hazardous waste would not react or be otherwise incompatible with the hazardous waste being stored so that the ability of the containers to contain the waste was not impaired, in violation of 40 C.F.R. �� 262.34(d)(2) and 265.172, which is incorporated by reference in the authorized Pennsylvania Hazardous Waste Program, 25 Pa. Code Ch. 262. Violation 6: Prior to June 22, 2004, Cedar Crest College, a small quantity handler of universal waste as that term is used by 40 C.F.R. �� 273.9, failed to develop and implement universal waste management procedures and to train employees in violation of 40 C.F.R. ���� 273.10-273.20, which is incorporated by reference in the authorized Pennsylvania Hazardous Waste Program, 25 Pa. Code Ch. 262. Violation 7: Cedar Crest College has failed to meet the above-cited conditions to qualify for exemption from the RCRA requirements; therefore Cedar Crest College has not been exempt from the permitting requirements set forth in 25 Pa. Code Ch. 270a (40 C.F.R. Part 270). Accordingly, the storage of hazardous waste at the Cedar Crest College facility without a hazardous waste permit or interim status is a violation of 25 Pa. Code �� 270a and RCRA Section 3005, 42 U.S. C. �� 6925. Violation 8: Prior to July 8, 2004, Cedar Crest College failed to follow the instruction printed on the label of a registered pesticide in violation of Section 12(a)(1)(G) of FIFRA, 7 U.S.C. �� 136j(a)(1)(G). Community/Geographically-Based Initiative? Yes Other: Colleges and Universities

Defendants (1)

• CEDAR CREST COLLEGENamed in settlement

Facilities (2)

• CEDAR CREST COLLEGE

  CEDAR CREST BLVD, ALLENTOWN, PA, 18104

  Registry ID: 110001028637

• CEDAR CREST COLLEGE

  CEDAR CREST BLVD, ALLENTOWN, PA, 18104

  Registry ID: 110001028637

Statutes cited

• FIFRA 12A2G — Misuse
• RCRA 3007 — Record keeping, Inspection, Information Request
• EPCRA 313 — Toxic Chemical Release Reporting (TRI)
• RCRA 3010 — Notification of Hazardous Waste Activity
• CWA 301 — NPDES Discharge without a Permit
• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste
• CAA 112 — Hazardous Air Pollutants

Enforcement conclusions (1)

• CEDAR CREST COLLEGEentered 2005-09-27

  Primary law: CAA

Timeline (3 milestones)

• 2004-07-19Enforcement Action Data Entered
• 2005-09-27Enforcement Action Closed
• 2005-09-27Final Order Issued