The violations were observed during April 2010, when inspectors from EPA and the South Carolina Department of Health and Environmental Control performed a Resource Conservation and Recovery Act (RCRA) Compliance Evaluation Inspection. SCI manufactures paints and coatings primarily for the steel and farm implement industry. SCI also blends raw materials onsite to create custom coatings.
The settlement resolves several alleged violations that were noted during the inspection. The alleged violations include:
· Improper management of hazardous waste containers on site;
· Failure to provide a sufficient base beneath containers which held hazardous waste;
· Failure to make a hazardous waste determination;
· Failure to inspect all areas where hazardous waste containers are stored weekly;
· Failure to develop an employee training program to ensure compliance with hazardous waste management;
· Failure to update information contained in the contingency plan, along with failing to make arrangements with local police and hospital authorities regarding the contingency plan and submitting copies of the contingency plan to first responders.
SCI implemented the process changes to reduce the risk of release from hazardous waste containers. The changes include: labeling all containers with the necessary information; reducing the number of locations where short term storage occurs; changing container sizing; and completing all necessary waste determinations. SCI also applied a non-porous sealant to the base floor surface where the majority of hazardous waste containers are staged during regular operations.