EPA v. GLOBAL PATHOLOGY LABORATORY SERVICES, H&P LEGACY CORP.

Case summary

9/12/2012 - CONSENT AGREEMENT AND FINAL ORDER (CAFO) ISSUED, ASSESSING A PENALTY OF $84,600. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. ORDER ALLEGES: ON JULY 22, 2011, A REPRESENTATIVE OF THE EPA AND A REPRESENTATIVE FDEP PERFORMED A RCRA COMPLIANCE EVALUATION INSPECTION (CEI) OF CURRENT OWNER'S FACILITY, WHICH AT THE TIME WAS OWNED AND OPERATED BY PRIOR OWNER. THE FINDINGS OF THE CEI WERE DOCUMENTED IN A JUNE 22, 2012, NOTICE OF VIOLATION AND OPPORTUNITY TO SHOW CAUSE LETTER AND THE RCRA CEI REPORT. ON AUGUST 3, 2011, CURRENT OWNER RE-NOTIFIED FDEP AS A LQG OF HAZARDOUS WASTE. AT THE TIME OF THE CEI, TWO CONTAINERS OF HAZARDOUS WASTE WERE FOUND IN THE FACILITY'S LABORATORY AREA NEAR GENERATION POINTS (SATELLITE ACCUMULATION AREA) WITHOUT THE WORDS HAZAROUS WASTE OR WITH OTHER WORDS THAT IDENTITY THE CONTENTS OF THE CONTAINERS. THE EPA ALLEGES THAT THE PRIOR OWNER VIOLATED FLA. STAT. SECTION 403.722 (SECTION 3005 RCRA, FOR STORING HAZARDOUS WASTE WITHOUT PERMIT OR INTERIM STATUS, BECAUSE PRIOR OWNER FAILED TO MEET A CONDITION FOR EXEMPTION FROM THE REQUIREMENT TO OBTAIN A PERMIT OR INTERIM STATUS. AT THE TIME OF THE CEI, PRIOR OWNER FAILED TO CLOSE TWO 55-GALLON CONTAINERS OF SOLVENT WASTE (D001 AND F003) LOCATED IN THE FACILITY'S 90-DAY HAZARDOUS WASTE ACCUMULATION AREA. EPA ALLEGES THAT PRIOR OWNER VIOLATED FLA. STAT. SECTION 403.722 (SECTION 3005 OF RCRA, FOR STORING HAZARDOUS WASTE WITHOUT A PERMIT OR INTERIM STATUS, BY FAILING TO MEET THE REQUIREMENTS OF THE LQG PERMIT EXEMPTION. AT THE TIME OF THE CEI, THREE 55-GALLON DRUMS OF HAZARDOUS WASTE (D001 AND F003) WERE FOUND IN THE FACILITY'S 90-DAY HAZARDOUS WASTE ACCUMULATION WITH NO ACCUMULATION START DATE. EPA ALLEGES THAT PRIOR OWNER VIOLATED FLA. STAT. SECTION 403.722 (SECTION 3005 OF RCRA, FOR STORING HAZARDOUS WASTE WITHOUT A PERMIT OR INTERIM STATUS, BY FAILING TO MEET THE REQUIREMENTS OF THE LQG PERMIT EXEMPTION. AT THE TIME OF THE CEI, PRIOR OWNER WAS NOT CONDUCTING WEEKLY INSPECTIONS OF THE FACILITY'S 90-DAY HAZARDOUS WASTE ACCUMULATION AREA. AS A RESULT, PRIOR OWNER WAS NOT IN COMPLIANCE WITH THE WEEKLY HAZARDOUS WASTE CONTAINER INSPECTION AND RECORDKEEPING REQUIREMENTS. EPA ALLEGES THAT PRIOR OWNER VIOLATED FLA. STAT. SECTION 403.722 (SECTION 3005 OF RCRA) FOR STORING HAZARDOUS WASTE WITHOUT A PERMIT OR INTERIM STATUS BY FAILING TO MEET TWO REQUIRMENTS OF THE LQG PERMIT EXEMPTION. MULTIPLE VIOLATIONS LISTED IN THE CAFO IN VIOLATION OF RCRA SECTION 3002 AND 3005.

Defendants (1)

• GLOBAL PATHOLOGY LABORATORY SERVICES (SB)Named in complaintNamed in settlement

Facilities (2)

• GLOBAL PATHOLOGY

  16250 NW 59TH AVE, MIAMI LAKES, FL, 330147542

  Registry ID: 110016738397

• GLOBAL PATHOLOGY LABORATORY

  16250 NW 59TH AVE, MIAMI LAKES, FL, 330147542

  Registry ID: 110016738397

Statutes cited

• RCRA 3005 — Permits for Treatment, Storage, or Disposal of Hazardous Waste
• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• GLOBAL PATHOLOGY LABORATORY SERVICES, H&P LEGACY CORP.entered 2012-09-12

  Primary law: RCRA

  Federal penalty: $84,600

Timeline (4 milestones)

• 2012-09-12Complaint Filed/Proposed Order
• 2012-09-12Final Order Issued
• 2012-09-14Enforcement Action Data Entered
• 2012-09-18Enforcement Action Closed