EPA v. INTERNATIONAL AEROSPACE COATINGS, INC.

Case summary

12/9/20 - On 4/4/19 EPA conducted a compliance evaluation inspection. EPA observed Respondent had not made HW determinations on discarded PPE, paper, plastic and tape in a gray trash can marked Regular Trash Only in the Hangar 9 Front Aircraft Area and an accumulation of waste paint in the Product Storage Area. EPA observed Respondent had a closed 55-gal container in the Hangar 9 Rear Aircraft Area that was bulging. Respondent ID?d the container as storing HW D001, D007, D018, and F003 Spent Peroxide Paint (Stripper). During the CEI Respondent manually removed the bung cap. The container off gassed and white smoke emitted from the drum. Respondent failed to clearly mark the following containers in the < 90-day HW storage areas with the date each period of HW accumulation began: Respondent did not label or mark the following containers in < 90-day HW storage areas with the words HW : Respondent could not provide records to show its employees had received training. Respondent failed to minimize the possibility of an unplanned sudden or non-sudden release of HW: Green dust, which was also found in HW Filter Blankets (D007), was covering the walls, ceiling, and locker of the Hangar 9 Women's Locker Room; exhaust fan of the Hangar 9 Women's Locker Room did not have a filter; HW stripper wash wastewater (D007 and D023) from the Hangar 9 Front Aircraft Area was running across the concrete floor and accumulating on the floor in the Product Storage Area; HW stripper wash wastewater (D007 and D023) from a 6,500-gal aux tank, which was behind the HW Storage Area (HWSA), was discharged to the ground outside Hangar 9; and HW Paint Container Debris (Solids)(D007) was accumulating on the Hangar 9 Front Aircraft Area hangar floor. Respondent's contingency plan did not: Describe arrangements agreed to with the local police dept, fire dept, other emer response teams, emer response contractors, equipment suppliers, local hospitals or Local Emer Planning Cmte Include an up-to-date list of the names and emer phone numbers of all persons qualified to act as emer coord, and this list must be kept up to date; Include an up-to-date list of all emer equip; and Include an evac plan f/generator personnel. Respondent failed to ensure the following containers of HW in the < 90-day HW storage areas were kept closed: A Gaylord box with orange liner in Hangar 9 Front Aircraft Area storing HW Paint Container Debris (Solids)(D007); A wooden box in Hangar 9 Front Aircraft Area storing HW Paint Container Debris (Solids)(D007); 4 55-gal containers of HW Spent Peroxide Paint (Stripper)(D00l, D007, D018, and F003) and 1 55-gal drum of HW (D002) and Spent Acid Stripper (D007) in HWSA; and 1 Gaylord box of HW Paint Container Debris Solids)(D007) in HWSA. Respondent failed to ensure the following containers of HW in satellite accumulation areas (SAA) were kept closed: 2 55-gals containers of HW Paint Container Debris (Solids) (D007) in the Hangar 9 Front Aircraft Area; and 1 55-gal container of HW Spent Solvent Rags (Acet1) (D00l and F003) in the General Area. Respondent failed to mark the following containers of HW in SAAs with the words HW or with other words that ID the contents of the containers: 2 55-gal containers containing HW Spent Solvent Rags (Acet1) (D00l and F003) in 2 SAAs in the Small Paint Area; 1 55-gal container of HW Spent Solvent Rags (Acet1) (D001 and F003) in the Mixing Area; and 1 55-gal container of HW Paint Related Materials (Liquids) (D00l, D005, and F003) in the Mixing Area. Respondent was storing ignitable waste in the HWSA and Respondent had not conspicuously placed No Smoking signs in the area. Subsequently, Respondent sampled the wastewater directly from the 6,500-gal auxiliary tank behind the HWSA. Samples were analyzed for metals, volatiles and semi-volatiles. The 3/8/19, sample showed the chromium concentration was 6.88 mg/L. The 3/12/19, sample showed the 2-Methylphenol (o-Cresol) concentration was 699 mg/L.

Defendants (1)

• INTERNATIONAL AEROSPACE COATINGS, INC.Named in complaintNamed in settlement

Facilities (1)

• INTERNATIONAL AEROSPACE COATINGS INC

  102 SE ACADEMIC AVE HANGAR 9, LAKE CITY, FL, 32025-2002

  Registry ID: 110070207555

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)

• INTERNATIONAL AEROSPACE COATINGS, INC.entered 2020-12-09

  Primary law: RCRA

  Federal penalty: $74,600

Timeline (4 milestones)

• 2020-12-09Final Order Issued
• 2020-12-09Complaint Filed/Proposed Order
• 2020-12-31Enforcement Action Data Entered
• 2023-12-05Enforcement Action Closed