EPA v. P - T COUPLING

Case summary

SUBJECT/DATE COMPLIANCE ORDER AND NOTICE OF OPPORTUNITY FOR HEARING FILED AGAINST P T COUPLING CO ALSO KNOWN AS CENTRAL MACHINE AND TOOL COMPANY. DOCKET NO RCRA VI-504-H. * BACKGROUND INFO ON NOV 15, 1984, THIS CASE WAS REFERRED TO EPA BY OSDH FOR POSSIBLE ENFORCEMENT ACTION AS A NON-NOTIFIER. THROUGH A LEAD INSPECTION DONE BY ESD ON JAN 30, 1985, INFORMATION WAS OBTAINED TO CONCLUDE THAT THIS FACILITY IS INVOLVED IN HAZ WASTE ACTIVITY. * P T COUPLING CO CONDUCTS ITS BUSINESS BY MANUFACTURING DIES FOR ITS BRASS AND STEEL FOUNDRY THAT USES SANDS FOR MOULDS AT ITS FACILITY LOCATED AT 1414 EAST WILLOW ST, ENID, GARFIELD, COUNTRY, OK. * ON AUG 3, 1984, AND EMPLOYEE OF THE OSDH CONDUCTD A SAMPLING INSPECTION AT P T COUPLING CO. THE INSPECTION RESULTS SHOWED THAT CHROMIUM AND LEAD WERE PRESENT IN THE FOUNDRY SAND. THE LEVEL OF LEAD IN THE WASTE PILE WAS FOUND TO BE ABOVE THE EP TOXICITY LIMIT OF 5.0 MG/L THEREFORE, THE WASTE PILE CONTAINS EPA HAZ WASTE CODE D008, WHICH IS A SOLID WASTE LISTED UNDER 40 CFR 261.24 TABLE I. THE EPA WILL SHOW THAT P T COUPLING CO HAS VIOLATED THE FOLLOWING VIOLATIONS: 1. FAILURE TO NOTIFY 2. FAILURE TO FILE A FEDERAL PART A PERMIT APPLICATION 3. NO WASTE ANALYSIS PLAN 4. NO INSPECTION SCHEDULE OR LOG 5. NO PERSONNEL TRAINING 6. NO WRITTEN CLOSURE PLAN 7. FAILURE TO USE MANIFESTS 8. DISPOSAL AT UNPERMITTED FACILITY 9. FAILURE TO TEST FOR HAZ WASTE 10. FAILURE TO RECEIVE EPA ID NO AND OPERATING HW TO TRANSPORTER WITHOUT AN EPA ID NO. 11. FAILURE TO FILE A PERMIT APPLICATION. 12. FAILURE TO MAINTAIN ADEQUATE SECURITY. 13. FAILURE TO PROTECT, CONTAIN AND MANAGE A WASTE PILE. 14. NO BIENNIAL REPORTS. 15. FAILURE TO POST SECURITY WARNING SIGNS. 16. NO ARRANGEMENTS WITH LOCAL AUTHORITIES. 17. NO CONTINGENCY PLAN. 18. NO OPERATING RECORD. 19. NO FINANCIAL ASSURANCE FOR CLOSURE. 20. NO FINANCIAL ASSURANCE FOR SUDDEN ACCIDENTAL OCCUR- RENCES. * COMPLAINANT ISSUED A COMPLAINT, COMPLIANCE ORDER AND NOTICE OF OPPORTUNITY FOR HEARING AGAINST P T COUPLING COMPANY ON JUNE 18, 1985, FOR 58,000 ALLEGING THE VIOLATIONS LISTED HEREIN. * ON JAN 30, 1986, COMPLAINANT FILED A MOTION TO AMEND THE ABOVE-REFERENCED COMPLAINT DUE TO NEWLY DISCOVERED EVIDENCE. THE AMENDED COMPLAINT WOULD DROP VIOLATIONS CONTAINED IN NUMBER 7, 8 AND 10 ABOVE, AND WILL REDUCE THE AMOUNT OF THE PROPOSED PENALTY FOR NUMBER 13. THUS, THE PROPOSED PENALTY FOR THE AMENDED COMPLAINT WAS REDUCED TO $40,000. * ON FEB 24, 1986, THE ADMINISTRATIVE LAW JUDGE, MARVIN JONES, ISSUED AN ORDER GRANTING COMPLAINANT LEAVE TO AMEND THE ORIGINAL COMPLAINT AS NOTED IN THE PREVIOUS PARAGRAPH. *

Defendants (1)

• P - T COUPLINGNamed in complaintNamed in settlement

Facilities (2)

• CENTRAL MACHINE & TOOL COMPANY

  1414 E. WILLOW, ENID, OK, 73702

  Registry ID: 110000454295

• CENTRAL MACHINE & TOOL COMPANY

  1414 E. WILLOW, ENID, OK, 73702

  Registry ID: 110000454295

Statutes cited

• RCRA 3008 — Res Conserv & Rec Act

Enforcement conclusions (1)

• P - T COUPLINGentered 1986-09-12

  Primary law: RCRA

  Federal penalty: $17,500

Timeline (4 milestones)

• 1985-06-17Enforcement Action Data Entered
• 1985-06-17Complaint Filed/Proposed Order
• 1986-09-12Final Order Issued
• 1987-01-28Enforcement Action Closed