EPA v. ANDERSON UNIVERSITY

Case summary

8/31/2011 - NOTICE OF DETERMINATION ISSUED. IN A SELF-DISCLOSURE DAGTED APRIL 17, 2009, ANDERSON UNIVERSITY DISCLOSED VIOLATION OF THE CAA, CWA, FIFRA, AND RCRA. ANDERSON UNIVERSITY CORRECTED ALL VIOLATIONS BY MAY 31, 2009. THE SELF-DISCLOSURE ALSO INCLUDED POTENTIONS OF THE CAA'S NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR ASBESTOS; THE REPORTING PROVISIONS OF EPCRA, AND THE PCB MAINTENANCE AND INVENTORY REQUIREMENTS OF TSCA. HOWEVER, EPA DETERMINED THAT THESE DISCLOSURES DID NOT CONSTITUTE VIOLATIONS OF FEDERAL LAW, AND THEREFORE, THEY WERE NOT REVIEWED UNDER THE AUDIT POLICY. VIOLATIONS: CAA: - NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANT FOR CONTAINERS; FAILURE TO MAINTAIN PROPER CLOSURES ON CHEMICAL CONTAINERS. CWA/SPCC: - UNAUTHORIZED DISCHARGE OF POLLUTANTS TO POTW. - CHEMICAL CONTAINERS STORED ABOVE SINK WITHOUT A SECONDARY CONTAINMENT. - FAILURE TO INSTALL SEDIMENT TRAPS TO CAPTURE CLAYS, ROCK DEBRIS AND SEDIMENT. - FUME HOODS WITH UNPROTECTED CUP HOODS AND FAILURE TO STORE HAZARDOUS MATERIALS IN SECONDARY CONTAINMENT. - FAILURE TO DEVELOP AND IMPLEMENT SPCC PLAN FOR FACILITY THAT POSSESSES GRATER THAN 1,320 GALLONS OF ABOVE-GROUND OIL STORAGE. - FAILURE TO PROVIDE SECONDARY CONTAINMENT FOR OIL CONTAINING VESSELS 55-GALLONS OR LARGER. - FAILURE TO TRAIN PERSONNEL IN SPCC PLAN REQUIREMENTS. - FAILURE TO CONDUCT INSPECTIONS OF AND MAINTAIN RECORDS FOR OIL CONTAINING VESSELS. - FAILURE TO PROPERLY MANAGE WASTE COOKING OIL. FIFRA: - USE OF REGISTERED PESTICIDE IN A MANNER INCONSISTEN WITH ITS LABELING. RCRA: - FAILURE TO MANAGE MATERIAL FROM SEDIMENT TRAPS AS POTENTIALLY HAZARDOUS WASTE. - FAILURE TO MANAGE FILTERS FROM PAINT SPRAY BOOTH AS POTENTIALLY HAZARDOUS WASTE. - DISPOSAL OF POTENTIALLY HAZARDOUS WASTE TO REGULAR TRASH. - FAILURE TO CONDUCT WASTE CHARACTERIZATIONS, DETERMINATIONS. - FAILURE TO MANAGE OILY RAGS AS POTENTIALLY HAZARDOUS WASTE. - FAILURE TO MANAGE AEROSOL SPRAY CANS AS POTENTIALLY HAZARDOUS WASTE; DISPOSED TO REGULAR TRASH. - HAZARDOUS WASTE CONTAINERS GROWING CRYSTALS. - FAILURE TO PROPERLY STORE UNIVERSAL WASTE PRIOR TO DISPOSAL. - FAILURE TO PROPERLY LABEL CONTAINERS STORING USED OIL.

Defendants (1)

• ANDERSON UNIVERSITYNamed in settlement

Facilities (1)

• ANDERSON UNIVERSITY

  316 BOULEVARD, ANDERSON, SC, 29621

  Registry ID: 110044232256

Statutes cited

• FIFRA 12A2G — Misuse
• CAA 112 — Hazardous Air Pollutants
• CWA 301/402 — NPDES Permit Violations
• CWA 311J — SPCC and/or Federal Response Plan Violations
• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• ANDERSON UNIVERSITYentered 2011-08-31

  Primary law: RCRA

Timeline (3 milestones)

• 2011-08-31Final Order Issued
• 2011-08-31Enforcement Action Closed
• 2011-09-11Enforcement Action Data Entered