EPA v. REESE AFB - REESE AFB, TX

Case summary

SUBJECT: * RCRA 3008 NOTICE OF NONCOMPLIANCE, COMPLIANCE SCHEDULE AND NOTICE OF NECESSITY FOR CONFERENCE. * BACKGROUND: * REESE AIR FORCE BASE IS A REFERRED CASE FROM THE TEXAS WATER COMMISSION (TWC). * REESE AIR FORCE BASE SUBMITTED AN AFFADAVIT OF EXCLUSION TO TWC IN WHICH THEY CLAIMED TO BE A SMALL QUANTITY GENERATOR AND HAVE LESS THAN 90 DAYS STORAGE. THIS FACILITY HAS TWO SURFACE IMPOUNDMENTS. ONE SURFACE IMPOUNDMENT RECEIVES INDUSTRIAL WASTE (NON-POTABLE WATER LAKE NPW LAKE) AND THE OTHER SURFACE IMPOUNDMENT RECEIVES WASTE FROM SEWAGE TREATMENT PLANT (SEWAGE LAGE). BOTH ARE CONNECTED. * THE NPW LAKE AND SEWAGE LAKE SHOULD BE SUBJECT TO RCRA REQUIREMENTS AND SHOULD HAVE CERTIFIED FOR LOIS PROVISIONS. REESE AIRFORCE BASE DID NOT CERTIFY, THUS THESE SURFACE IMPOUNDMENTS HAVE LOST INTERIUM STATUS. CLOSURE PLANS SHOULD HAVE BEEN SUBMITTED. * A FACTS MEETING WAS HELD ON JULY 17, 1986, IN WHICH THE SQG AND THE SHORT TERM STORAGE ISSUES WERE DISCUSSED. BOTH PARTIES AGREED ADDITIONAL INFORMATION WOULD BE FURNISHED TO DETERMINE WHETHER FACILITY IS IN VIOLATION OF STORAGE REGULATIONS. THE STORAGE VIOLATIONIS ADDRESSED IN THE ORDER. THE FOLLOWING VIOLATIONS WERE NOTED: - FAILURE TO SUBMIT A BIENNIAL REPORT; - FAILURE TO HAVE AN ADEQUATE WRITTEN WASTE ANALYSIS PLAN; - FAILURE TO HAVE ADEQUATE SECURITY; - FAILURE TO POST WARNING SIGNS; - FAILURE TO DEVELOP AN ADEQUATE INSPECTION SCHEDULE; - FAILURE TO DEVELOP AN ADEQUATE INSPECTION LOG OR SUM- MARY; - FAILURE TO ENSURE FACILITY PERSONNEL ARE ABLE TO RESPOND TO EMERGENCIES; - FAILURE TO CONDUCT ANNUAL TRAINING; - FAILURE TO CONDUCT AND DOCUMENT AN ADEQUATE PERSONNEL TRAINING PROGRAM; - FAILURE TO PROVIDE AN INTERNAL COMMUNICATIONS OR ALARM SYSTEM; - FAILURE TO HAVE PHONE NUMBERS AND AGREEMENTS WITH STATE EMERGENCY RESPONSE TEAMS; - FAILURE TO INCLUDE THE DRUM STORAGE AREA AND THE SUR- FACE IMPOUNDMENT IN THE CONTINGENCY PLAN; - FAILURE TO AMEND THE CONTINGENCY PLAN TO RELECT CHANGES; - FAILURE TO MAINTAIN AND OPERATE THE SURFACE IMPOUND- MENT TO PREVENT ANY ENDANGERMENT OF PUBLIC HEALTH AND SAFETY; - FAILURE TO INSPECT THE SURFACE IMPOUNDMENT FOR MALFUNC- TIONS; - PLACING IGNITABLE WASTES IN A SURFACE IMPOUNDMENT; - FAILURE TO DEVELOP AND MAINTAIN A WRITTEN CLOSURE PLAN; - FAILURE TO IMPLEMENT A GROUNDWATER MONITORING PROGRAM; - FAILURE TO TIMELY SUBMIT A CLOSURE PLAN TO THE STATE; - STORING HAZ WASTE WITHOUT A PERMIT OR INTERIM STATUS; - TREATING HAZ WASTE IN A SURFACE IMPOUNDMENT; - FAILURE TO PERFORM WASTE ANALYSIS; AND - PROHIBITIONS ON LAND DISPOSAL. *

Defendants (1)

• REESE AFBNamed in complaint

Statutes cited

• RCRA 3008A — Compliance Order: Injunctive & Penalty

Timeline (5 milestones)

• 1988-06-12Enforcement Action Data Entered
• 1988-06-12Complaint Filed/Proposed Order
• 1992-09-20Final Order Issued
• 1999-06-22Compliance Achieved
• 1999-06-22Enforcement Action Closed