EPA v. DENSO MANUFACTURING TENNESSEE, INC.

Case summary

SEPTEMBER 15, 2021 - CONSENT AGREEMENT AND FINAL ORDER ISSUED: On December 8, 2020, the EPA and TDEC conducted a compliance evaluation inspection (CEI) at the Respondent's Facility. The EPA's findings of the CEI were documented in a report mailed to the Respondent, dated February 11, 2021.At the time of the inspection, the EPA inspector observed that the Respondent failed to write an accumulation start date on each container of off-specification/expired printing inks (D001), located in the Chemical Storage Room of Plant 201. At the time of the inspection, the EPA inspector observed that the Respondent failed to write an accumulation start date on one 55-gallon container of hazardous waste contaminated debris located in the Hazardous Waste Central Accumulation Area (CAA) in the Recycle Center of Plant 203. At the time of the inspection, the EPA inspector observed that the Respondent failed to label each container of off-specification/expired printing inks (D001) with the words Hazardous Waste, located in the Chemical Storage Room of Plant 201. In the screen wash unit, Respondent generates a spent solvent that has an average volatile organic concentration of at least 10 percent by weight. At the time of the inspection, the EPA inspector observed that the equipment that the Respondent uses to manage spent solvent from the screen wash unit is in light liquid service. At the time of the inspection, there was no visible evidence or record-retaining documentation indicating each piece of equipment used to convey the spent solvent from the screen wash unit to the solvent distillation unit was marked in a manner that would allow it to be distinguished readily from other pieces of equipment. At the time of the inspection, there were no records provided that would show that the pump used to transfer spent solvent from the screen wash unit into a 300-gallon container was monitored monthly to detect leaks by methods specified in Tenn. Comp. R. & Regs. 0400-12-01- .05(28)(n) [40 CFR 265.1063(b)]. At the time of the inspection, there were no records provided that would show that the valves in the flexible hose system used to transfer the spent solvent from the screen wash unit to the solvent distillation unit were monitored monthly to detect leaks by methods specified in Tenn. Comp. R. & Regs. 0400-12-0l-.05(28)(n) [40 CFR 265.1063(b)]. At the time of the inspection, the EPA inspector observed that the Respondent was not maintaining records for each piece of equipment to which Tenn. Comp. R. & Regs. 0400-12-01-.05(28) [40 CFR Part 265, Subpart BB] applies in the facility's operating record.

Defendants (1)

• DENSO MANUFACTURING TENNESSEE, INC.Named in complaintNamed in settlement

Facilities (9)

• DENSO MANUFACTURING TENNESSEE INC.

  1725 ROBERT C. JACKSON DRIVE, MARYVILLE, TN, 37801

  Registry ID: 110070733650

• DENSO MANUFACTURING TENNESSEE INC.

  1725 ROBERT C. JACKSON DRIVE, MARYVILLE, TN, 37801

  Registry ID: 110070733650

• DENSO MANUFACTURING TENNESSEE INC.

  1725 ROBERT C. JACKSON DRIVE, MARYVILLE, TN, 37801

  Registry ID: 110070733650

• DENSO MANUFACTURING TENNESSEE INC.

  1725 ROBERT C. JACKSON DRIVE, MARYVILLE, TN, 37801

  Registry ID: 110070733650

• DENSO MANUFACTURING TENNESSEE INC.

  1725 ROBERT C. JACKSON DRIVE, MARYVILLE, TN, 37801

  Registry ID: 110070733650

• DENSO MANUFACTURING TENNESSEE INC.

  1725 ROBERT C. JACKSON DRIVE, MARYVILLE, TN, 37801

  Registry ID: 110070733650

• DENSO MANUFACTURING TENNESSEE INC.

  1725 ROBERT C. JACKSON DRIVE, MARYVILLE, TN, 37801

  Registry ID: 110070733650

• DENSO MANUFACTURING TENNESSEE INC.

  1725 ROBERT C. JACKSON DRIVE, MARYVILLE, TN, 37801

  Registry ID: 110070733650

• DENSO MANUFACTURING TENNESSEE INC.

  1725 ROBERT C. JACKSON DRIVE, MARYVILLE, TN, 37801

  Registry ID: 110070733650

Statutes cited

• RCRA 3005 — Permits for Treatment, Storage, or Disposal of Hazardous Waste
• RCRA 3003 — Standards Applicable to Transporters of Hazardous Waste

Enforcement conclusions (1)

• DENSO MANUFACTURING TENNESSEE, INC.entered 2021-09-15

  Primary law: RCRA

  Federal penalty: $28,500

Timeline (4 milestones)

• 2021-09-15Complaint Filed/Proposed Order
• 2021-09-15Final Order Issued
• 2021-09-15Enforcement Action Data Entered
• 2021-09-20Enforcement Action Closed