EPA v. SNF HOLDING COMPANY

Case summary

2/16/17 - CONSENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $5,700, DUE WITHIN 30 DAYS. ALLEGATIONS: RESPONDENT MANUFACTURES VARIOUS ACRYLATE PRODUCTS AT THE ACRYLATES FACILITY. AS A RESULT OF ITS MANUFACTURING OPERATIONS, THE ACRYLATES FACILITY GENERATES A D001 CHARACTERISTIC HAZ WASTE. ON MAY 13, 2016, RESPONDENT SUBMITTED A NOTIFICATION OF HAZ WASTE ACTIVITY FOR THE ACRYLATES FACILITY PURSUANT TO RCRA 3010(a) AS AN LQG OF HAZ WATE. RESPONDENT NOTIFIED AS BEING A GENERATOR OF A D001 CHARACTERISTIC HAZ WASTE. ON JULY 19, 2016, EPA CONDUCTED A COMPLIANCE EVALUATION INSPECTION (CEI) AT RESPONDENT'S FACILITIES. THE FINDINGS OF THE CEI WERE DOCUMENTED IN A REPORT MAILED TO RESPONDENT, DATED OCT 24, 2016. DURING THE JULY 19, 2016, CEI, EPA OBSERVED RESPONDENT TO BE ACCUMULATING D001 CHARACTERISTIC HAZ WASTE WITHIN TANK V-550 FOR LESS THAN 90 DAYS. EPA OBSERVED THAT RESPONDENT HAD PLACED GRATING ON THE BASE OF THE SECONDARY CONTAINMENT SYSTEM FOR TANK V-550. THE GRATING PREVENTED THE FACILITY FROM BEING ABLE TO INSPECT THE ENTIRE SECONDARY CONTAINMENT SYSTEM FOR THE TANK. EPA THEREFORE ALLEGES RESPONDENT VIOLATED SECTION 12-8-66 OF THE GHWMA, GA CODE ANN SECTOIN 12-8-66 (RCRA 3005) BY STORING HAZARDOUS WATE W/OUT A PERMIT OR INTERIM STATUS, BECAUSE RESPONDENT FAILED TO MEET A CONDITION OF THE LQG PERMIT EXEMPTION SET FORTH IN GA COMP. R. AND REGS 391-3-11-.08(1) (40 CFR 262.34(a)(1)(ii)) BY NOT INSPECTING TANK V-550 AS REQUIRED BY GA. COMP. R. AND REGS 391-3-11-.10(1) (40 CFR 265.195).

Defendants (1)

• SNF HOLDING COMPANYNamed in complaintNamed in settlement

Facilities (50)

• SNF RICEBORO PLANT

  1 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF RICEBORO PLANT

  1 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF HOLDING COMPANY, INC.

  674 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF RICEBORO PLANT

  1 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF RICEBORO PLANT

  1 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF RICEBORO PLANT

  1 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF HOLDING COMPANY, INC.

  674 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF HOLDING COMPANY, INC.

  674 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF HOLDING COMPANY, INC.

  674 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF RICEBORO PLANT

  1 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF RICEBORO PLANT

  1 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF RICEBORO PLANT

  1 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF RICEBORO PLANT

  1 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF HOLDING COMPANY, INC.

  674 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• SNF RICEBORO PLANT

  1 CHEMICAL PLANT ROAD, RICEBORO, GA, 31323

  Registry ID: 110027375775

• …and 35 more

Statutes cited

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

Enforcement conclusions (1)

• SNF HOLDING COMPANYentered 2017-02-16

  Primary law: RCRA

  Federal penalty: $5,700

Timeline (4 milestones)

• 2017-02-16Complaint Filed/Proposed Order
• 2017-02-16Final Order Issued
• 2017-03-01Enforcement Action Data Entered
• 2017-03-21Enforcement Action Closed