United States
Environmental Protection
Agency
Office of Enforcement and
Compliance Assurance (2261 A)
EPA 300-R-97-002
January 1997
Federal Facility Compliance Act
Enforcement: Analysis of RCRA
Administrative Orders Issued at Federal
Facilities (October 1992-December 1995)
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For more information or comments about this document, please contact:
Kelly Conrad
U.S. Environmental Protection Agency
Office of Enforcement and Compliance Assurance
Federal Facilities Enforcement Office
401 M Street, SW
MC-2261A
Washington, DC 20460
202/564-2459
conrad.kelly@epamail.epa.gov
Prepared by:
Logistics Management Institute under EPA contract number DASW01-95-C-0019
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EXECUTIVE SUMMARY
This study presents the results of an analysis of Administrative Orders (AOs) issued at Federal
facilities for violations of the Resource Conservation and Recovery Act (RCRA), as amended
by the Federal Facility Compliance Act (FFCA) of 1992. The study incorporates data
obtained directly from the ten EPA Regions and their counterpart offices at the State level for
the period October 1, 1992 to December 31, 1995. Twenty-nine AOs were issued by EPA
Regions since the effective date of the FFCA in October 1992 through December 1995.
Seventy-six State AOs were issued during the same period.
Objectives
A primary objective of the study was to organize RCRA violation and enforcement data from
AOs into a format that would facilitate more detailed analyses than previously possible from
existing databases and provide EPA Regions and State agencies this information as a tool to
assess their enforcement and compliance assistance programs. In addition, EPA's Federal
Facilities Enforcement Office (FFEO) wanted to have detailed information readily available to
quickly and accurately respond to inquiries about FFCA enforcement at Federal facilities. The
specific objectives of the study were to:
• complete detailed reviews of State and Federal (EPA issued) AOs to determine
agency/facility administrative data, time lines (e.g., issue and settlement dates),
specific violations cited, penalty amounts proposed and paid, Supplemental
Environmental Project (SEP) amounts (if any), and other pertinent information;
• compile the information into a user-friendly database system to facilitate information
update, ongoing analyses, and future development of a periodic FFCA Analysis
Report;
• and identify the specific nature, frequency and types of Federal facility violations and
associated penalties for use by regulated Federal agencies and regulators to determine
where areas of non-compliance exist.
Methodology
To facilitate the analysis, a three-digit alphameric coding system was developed to classify
specific violation and penalty data. The data were uploaded into the database Microsoft
Access. Many State AOs did not provide a precise breakdown of the penalty proposed for each
violation cited (some orders contained as many as 26 separate violations). This made it
infeasible to draw meaningful comparisons between State penalty assessments for similar
violations at the federal level.
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Several data limitations surfaced during the study. The principal areas include the following:
• State enforcement agencies do not routinely assign specific penalty/SEP information to
each corresponding violation in AOs as is presently done in the Federal AOs. Doing so
would allow a complete and accurate analysis of State AOs. A total of only 373 of 701
violations in the 105 orders had a clear corresponding penalty amount.
• At the conclusion of this study, only 55 of 105 AOs had been finalized. Therefore, the
analysis of the final penalties assessed is incomplete.
• This analysis does not permit drawing conclusions about specific root causes of
violations. Regulating agencies and facilities may be better able to focus their
training and compliance assistance programs with this type of information.
Summary
This study principally involved the collection and detailed review of RCRA Federal and State
proposed (and final orders when available) administrative orders levied against Federal facilities
from October 1992 through December 1995.
Major findings include the following:
• A total of 105 RCRA administrative orders were issued at 80 Federal facilities
representing 11 Federal agencies from October 1992 through December 1995.
• 29 orders (28 percent) were issued by EPA Regions and 76 orders (72 percent) were
issued by State enforcement agencies.
• 77 Federal and State orders (73 percent) were issued against facilities located in EPA
Regions IV, VI, and K.
• The average settlement time was 369 days for Federal orders and 196 days for State
orders.
• During the study period, EPA proposed a total of $9,335,722 in penalties and States a
total of $4,154,484.
• The average Federal proposed penalty was $321,921 per order. The average State
proposed penalty was $54,664. The combined average for proposed orders was
$128,478.
• In most instances, proposed penalties were mitigated in the final orders. However, the
smaller the initial proposed penalty, the more likely the final penalty would be the same
as the initial proposed penalty.
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• Seven orders (three State and four Federal) included specific SEP costing data. The
Federal SEP total was $2,087,869 and the State SEP total was $60,736.
• A total of 701 individual violations were cited in the 105 orders. Of those cited, the
majority (481— 69 percent) fell into five broad categories: 1) storage and accumulation
issues (135 violations); 2) general operations and maintenance failures (133
violations); 3) labeling deficiencies (87 violations); 4) safety (68 violations); and, 5)
records submissions (58 violations).
• The five most frequent specific violations were: 1) failure to label or improperly
labeled containers (86 violations); 2) incomplete or failure to make a hazardous waste
determination (57 violations); 3) failure to indicate accumulation or storage start dates
on containers (53 violations); 4) failure to close HW containers (43 violations); and,
5) failure to provide/maintain emergency response equipment (31 violations).
• Of the 701 violations cited, 199 were at Army facilities, 149 at Air Force facilities,
133 at Department of Energy facilities, and 130 at Navy facilities. Seven other Federal
agencies were collectively cited for the remaining 90 violations.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY E-l
INTRODUCTION 1
Background 1
Objectives 1
ADMINISTRATIVE ORDER COLLECTION AND DATABASE DEVELOPMENT 2
Administrative Order Collection 2
Administrative Order Review 2
Database Development and Violation Coding 3
ADMINISTRATIVE ORDER DISTRIBUTION 5
VIOLATIONS AND PENALTY ASSESSMENT 7
Breakdown by Second-Level Violation Category 7
Breakdown by Third-Level Violation Category 9
Summary of Ten Most Frequent Third-Level Violations and Penalties 12
Violations and Largest Average Penalties 13
ADMINISTRATIVE ORDER SETTLEMENT ANALYSIS 15
Average Negotiation Time to Final Settlement 15
Average Penalties Proposed and Final (EPA Regional perspective) 15
Average Penalties Proposed and Final (Federal Agency perspective) 18
Supplemental Environmental Projects (SEPs) 19
DAT A LIMITATIONS 21
SUMMARY 22
LIST OF FIGURES
Figure 1. RCRA AOs Issued to Federal Facilities Oct 92-Dec 95 5
Figure 2. RCRA AOs Issued to Federal Facilities Oct 92-Dec 95 (by EPA Region) ... 6
Figure 3. RCRA AOs Issued to Federal Facilities Oct 92-Dec 95 (by Agency) 7
Figure 4. Frequency of 709 Violations by Second-Level Category (w/code) 9
Figure 5. Frequency of Third-Level Storage and Accumulation Violations 10
Figure 6. Frequency of Third-Level Operations and Maintenance Violations 10
Figure 7. Frequency of Third-Level Labeling Violations 11
Figure 8. Frequency of Third-Level Security and Safety Violations 11
Figure 9. Frequency of Third-Level Record Submission Violations 12
Figure 10. Five Largest Average Proposed Penalty Amounts for
Second-Level Violation Categories 13
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Figure 11. Five Largest Average Proposed Penalty Amounts for
Third-Level Violation Categories 14
Figure 12. Average Proposed Penalty Amounts Federal vs. State 15
Figure 13. Average Federal Penalty Amounts Proposed vs. Final 16
Figure 14. Average State Penalty Amounts Proposed vs. Final 17
Figure 15. Average Federal Penalty Amounts Proposed vs. Final 18
Figure 16. Average State Penalty Amounts Proposed vs. Final 19
LIST OF TABLES
Table 1. Dlustration of Coding System Used 4
Table 2. Database Fields and Example Entries or Description 4
Table 3. Breakdown of 709 Violations by Second Level Violation Category 8
Table 4. Ten Most Frequent Third-Level Violations and Average Proposed Penalty .. 13
Appendix A. RCRAFindings Codes A-l
Appendix B. Summary of RCRA Violations by Category B-l
Appendix C. Summary of RCRA AOs and Violations by Agency C-l
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KEY STUDY FINDINGS
A total of 105 RCRA administrative orders were issued from October 1992 through December
1995 at 80 Federal facilities representing 11 Federal agencies.
29 orders (28 percent) were issued by EPA Regions and 76 orders (72 percent) were issued by
State enforcement agencies.
77 orders (73 percent) were issued against faculties located in Regions IV, VI, and IX.
The number of AOs issued rose from CY92 (three orders) to CY93 (54 orders), then declined
from CY93 to CY94 (36 orders,) and again decreased in CY95 (12 orders).
The average settlement time was 369 days for Federal orders and 196 days for State orders.
During the study period, EPA proposed a total of $9335,722 in penalties and States a total of
$4,154,484.
The average Federal proposed penalty amount per administrative order was $321,921. The
average State proposed penalty amount was $54,664. The average combined proposed penalty
was $128,478. Generally, proposed penalties for Federal orders were higher than State orders.
In most instances, proposed penalties were higher than final penalties. However, the smaller the
initial proposed penalty, the more likely the final penalty would be the same as the initial
proposed amount
Seven orders (three State and four Federal) included specific supplemental environmental
project (SEP) costing data. The Federal SEP total was $2,087,869 and the State total was
$60,736.
A total of 701 individual violations were cited in the 106 orders. Of those cited, the majority
(481 violations, or 69 percent) fell in five broad categories: 1 - storage and accumulation issues
(135 violations), 2 - general operations and maintenance failures (133 violations), 3 - labeling
deficiencies (87 violations), 4 - safety (68 violations), and 5 - records submissions (58 violations).
The five most frequent specific violations were: 1 - failure to label or improperly labeled
containers (86 violations), 2 - incomplete or failure to make a hazardous waste determination (57
violations), 3 - failure to indicate accumulation/storage start dates on containers (53 violations),
4 - failure to close HW containers (43 violations), and 5 - failure to provide/maintain emergency
response equipment (31 violations).
Of the 701 violations cited, 199 were at Army faculties, 149 at Air Force faculties, 133 at
Department of Energy facilities, and 130 at Navy facilities. The remaining seven Federal
agencies (USDA, NASA, USMC, Dol, DLA, USCG, and Air NG) were collectively cited for the
remaining 90 violations.
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ACRONYMS
Air NG Air National Guard
AO administrative order
CA/FO Compliance Agreement Final Order
CY calendar year
DLA Defense Logistics Agency
DoD Department of Defense
DoE Department of Energy
Dol Department of the Interior
EPA United States Environmental Protection Agency
FFCA Federal Facility Compliance Act of 1992
FFEO Federal Facilities Enforcement Office
FFTS Federal Facilities Tracking System
LDR land disposal restrictions
NASA National Aeronautics and Space Administration
RCRA Resource Conservation and Recovery Act
RCRIS Resource Conservation and Recovery Information System
SAA satellite accumulation area
SEP supplemental environmental project
US AF United States Air Force
USCG United States Coast Guard
USDA United States Department of Agriculture
USMC United States Marine Corps
IV
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INTRODUCTION
This study presents the results of an analysis of Administrative Orders issued at Federal
facilities for violations of the Resource Conservation and Recovery Act (RCRA), as amended
by the Federal Facility Compliance Act of 1992 (FFCA). The report incorporates data
obtained directly from the ten EPA Regions and their counterpart offices at the State level for
the period October 1, 1992 to December 31, 1995.
Background
RCRA requires that Federal facilities achieve and maintain compliance under RCRA to the
same degree as their non-Federal counterparts. The FFCA clarifies RCRA's waiver of
sovereign immunity and stipulates that RCRA's substantive and procedural requirements, as
well as all State and local hazardous waste regulations, fully apply to Federal facilities. Under
this waiver, EPA and the States have the authority to issue orders and assess penalties against
Federal facilities for RCRA violations. Typically, a Complaint and Compliance Order is first
issued to a non-compliant facility; then after negotiations, a Consent Agreement/Final Order
(CA/FO) is issued. For purposes of this report, the term "proposed order" refers to the
Complaint and Compliance Order and "final order" refers to the CA/FO. In addition to
imposing civil penalties, authorized States have the option to pursue civil judicial actions
against non-compliant Federal facilities.
The Federal Facilities Enforcement Office (FFEO) at EPA Headquarters began tracking
RCRA 3008(a) Federal AOs and State issued AOs during the first quarter of FY93. This
initial effort focused on capturing the cumulative number of orders issued against Federal
facilities, the total amounts of Federal and State proposed penalties, final penalty amounts
assessed, and the extent to which supplemental environmental projects (SEPs) were being used
as a settlement factor in determining the final penalty. A limited preliminary analysis was also
conducted on a representative sampling of administrative orders to determine the nature of
typical violations that resulted in the issuance of AOs.
Objectives
In this follow-on study, the FFEO sought to capture additional data in a format that would
allow a detailed analysis of violations at Federal facilities in order to better address
deficiencies and to respond to inquiries (internal and external) about enforcement at Federal
facilities.
There was also a need to expand the level of detail of AO data available such as: penalties
(proposed and final); the use of SEPs; and to build the capability to analyze and present this
information from a variety of perspectives (e.g., by Region, State, Federal agency, violation
category, frequency).
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To address these needs, the FFEO began a follow-on study in June 1995 with the following
principal objectives:
• complete detailed reviews of State and Federal AOs to determine agency/facility
administrative data, time lines (e.g., issuance and settlement dates), specific violations
cited (where available), penalty amounts assessed and paid, SEPs (if any), and other
pertinent information;
• identify the specific nature, frequency and types of Federal facility violations and
associated penalties for use by regulated Federal agencies and regulators to determine
where the areas of non-compliance exist; and,
• compile the information into a user-friendly, off-the-shelf database system to facilitate
information update, ongoing analyses, and future development of a periodic FFCA
Analysis Report.
ADMINISTRATIVE ORDER COLLECTION AND DATABASE DEVELOPMENT
Administrative Order Collection
Although HQ EPA databases (such as RCRIS and FFTS) and other program support offices
undertake limited tracking of AOs, information available from those sources was found to be
insufficiently detailed for this report. Accordingly, requests for copies of the 105 AOs were
made directly to EPA Regional Federal Facility Coordinators and State RCRA enforcement
agency offices. This phase of the study began in August 1995 and continued through March
1996.
Administrative Order Review
In order to develop a comprehensive set of baseline data, each AO was reviewed in detail to
determine specific violations, associated penalties and SEP information. In particular, every
effort was made to identify individual violations of the RCRA statute or regulations within each
AO (some AOs contained as many as 26 different counts) in order to facilitate an in-depth
analysis of the deficiencies and trends.
In the case of Federal orders, this task was relatively easy because of the use of a standardized
format for the orders. The violation section of each Federal order was broken down into specific
violations and corresponding penalties. Penalty amounts for each violation were then added to
reflect the total assessment made in the AO against a Federal facility.
Unfortunately, for the majority of State-issued orders (76 of the 105 identified AOs were State
orders), it was not possible to correlate a penalty amount for individual violations. In large part,
State AOs reported multiple violations, but only reported a single, all-encompassing penalty,
with no indication of what portion was assessed for which violation. Attempts were made to
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secure this material, but it ultimately proved infeasible to further break down the information.
This lack of uniformity in the violation breakdown in the Administrative Orders does not provide
a complete picture of the violation and penalty data, and affects the analysis of frequency of
specific violations and penalties associated with each violation.
Another barrier to a complete final penalty analysis was that 50 of the 105 AOs were still under
negotiation at the time of the completion of this study. Because of this, final penalty and/or SEP
information was not available for the entire universe of AOs. This reduced the number of orders
that could be used to perform a complete analysis such as the amounts of proposed penalties vs.
amounts actually paid once final settlements had been negotiated.
Database Development and Violation Coding
In order to capture the data in a format that would facilitate detailed analysis, a database was
developed using Microsoft Access Version 2.0. In conjunction with the database, a coding
system1 was devised to enable entering much more detailed violation and penalty data than was
previously possible.
With this system, individual violations were assigned a three-digit alphameric findings code
(e.g., 44a). The first digit of the violation indicates one of eight first-level categorization. They
are: exceedances [1]; technical work [2]; personnel [3]; operations [4]; spills/leaks/discharges
[5]; facilities problems [6]; general management [7]; and legal obligations [8]. The first two
digits taken together, therefore, designate the first and second level findings group (e.g., code 44
= storage and accumulation issues). To further define the violation, a third level findings group
was created by augmenting the two-digit code with an alphabetic tag (e.g., code 44a = storage
beyond permitted time limits which is a storage and accumulation issue [44]). Table 1 illustrates
this concept further using four separate violations taken from one order issued against the
Army's Aberdeen Proving Ground, MD.
By using this coding system, each separate count became a unique record in the database. For
the 105 orders involved, a total of 701 violations were captured as unique records. Altogether, a
total of 17 fields were used to build the database. They are briefly described in Table 2.
The coding system was originally developed by the Logistics Management Institute for the Department of the Army.
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Table 1. Illustration of coding system used.
Count
1
2
3
4
FmdiaigCode
44c
47g
47d
47h
" Second Level Violation Description
Storage and accumulation issues (44)
Manifest and transport problems, LDR
certification (47)
Manifest and transport problems, LDR
certification (47)
Manifest and transport problems, LDR
certification (47)
Third Level Violation Description
Storage beyond permitted time limits (44c)
LDR notification failure (47g)
LDR certification requirements (47d)
Failure to obtain date and/or number of
manifest (47h)
A complete description of the entire coding system is at Appendix A.
Table 2. Database fields and example entries or description.
Facility Name
State
Region
Department
Docket*
Count
Finding code
Violation category
Violation description
Total proposed penalty
Date issued
Status
Violation penalty
SEPs
Date settled
Amount paid
Agency
swSf^v^tSSrF •" I* **. *"•*<• '-•> »•?• s *>
fe-'£??v**' ?*£/*}•* .lExampleTsntry or Description ' -• - -5
Aberdeen Proving Ground
MD
03
Federal agency that owns the facility (e.g. Army)
3-R-94084
1, 2, 3, depending on total number of specific violations cited
3-digit alphameric code as described above (e.g., 44c)
First level findings group in which count falls (e.g., storage and accumulation issues)
Second level findings group (e.g., storage beyond permitted time limits)
Total penalty amount originally assessed
Date AO was issued
Final or under negotiation
Portion of total proposed penalty amount applied to a specific violation
Amount of SEPs, if any
Date of final negotiated settlement
Amount of penalty actually paid at settlement
Agency that issued AO (EPA or State)
A complete listing of all database records by Agency is at Appendix C.
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ADMINISTRATIVE ORDER DISTRIBUTION
A total of 105 Administrative Orders issued at 80 Federal facilities belonging to 11 Federal
agencies were included in the database.
Figure 1. RCRA AOs Issued to Federal Facilities
Oct 92-Dec 95
Federal - 29
State - 76
*Oct-Dec 92 only
1993 1994
Calendar year
1995
A total of 105 Federal and State RCRA administrative
orders were issued from October 1992 to December 1995.
Figures 1, 2 and 3 provide summary information for the AOs by calendar year issued, EPA
Region, and cited agency, respectively. Figure 1, above, shows that 76 of the 105 orders were
issued by the States while 29 were issued by EPA, reflecting the fact that RCRA enforcement
has been largely delegated to the States.
From an EPA Regional perspective, Figure 2 shows that almost three-quarters (73%) of all
AOs were issued in Region IV (18 orders-17%), Region VI (19 orders--18%) and Region IX
(40 orders-38%). States in these same three EPA Regions issued almost 86% (65 AOs) of the
State-issued AOs.
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Figure 2. RCRA AOs Issued to Federal Facilities
Oct 92-Dec 95 (by EPA Region)
Federal - 29
State - 76
Number of AOs issued
40 r
30
20
10
16 16
i^.r
• State
D Federal,
i
I II III IV V VI VII Mil IX X
Region
Almost three-quarters of all AOs were issued by EPA and State agencies to
Federal facilities located in EPA Regions IV, VI, and IX.
From a Federal agency perspective, Figure 3 below shows that the DoD departments of Army,
Air Force and Navy collectively received 75 (71%) of the 105 AOs issued. The DoD agencies
also operate the majority3 (46.9%) of the Federal RCRA regulated activities across the country,
many of which support substantial industrial activities. Of the DoD services, the Army received
the largest number of all AOs (30 orders-28.6%).
JFrom "The State of Federal Facilities: An Overview of Environmental Compliance at Federal Facilities
FY 1993-94" EPA Document 300-R-96-002.
6
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Figure 3. RCRA AOs Issued to Federal Facilities
Oct 92-Dec 95 (by Federal Agency)
Federal - 29
State - 76
Number of AOs issued
25r
20- „
0
5
a
, 2 i
ll
State
— Federal
Army Navy USDA USMC DLA Air NG
USAF DoE NASA Dol USCG
Agency
The DoD departments of Army, Air Force, and Navy
collectively received 71% of all AOs issued.
VIOLATIONS AND PENALTY ASSESSMENT
Breakdown by Second Level Violation Category
Review of the 105 orders resulted in the identification and categorization of 701 separate
violations. State enforcement agencies do not routinely assign a corresponding penalty amount
to each violation in AOs as is done in Federal EPA orders. A total of 373 of the 701 violations
had a clear corresponding penalty amount in the AOs. Therefore, only the number of
violations that had a definite associated penalty amount were used to calculate an average
penalty. Penalty amounts listed as "NA" indicate that no corresponding proposed penalty
amounts could be determined from an AO. The frequency of the 701 violations by second-level
category is provided in Table 3, along with the average proposed penalty amount from Federal
and State orders.
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^
J
Table 3. Breakdown of 701 violations by second level violation category.
Second level
Violation
Category
44
45
43
72
42
47
41
73
71
49
33
46
22
48
51
63
56
83
54
52
64
76
TOTAL
Frequency
135
133
87
68
58
53
41
39
21
18
17
5
5
5
4
3
2
2
2
1
1
1
701
Description
Storage and accumulation issues
General O&M failures
Labeling deficiencies
Security and safety
Record submissions (incomplete or late)
Manifest and transport problems, LDR certification
Unpennitted and unauthorized activity
Forms, documents, plans, manuals, etc,-inadequate/incomplete
Reports
Inspections and engineering certification
Training - inadequate or not done
Faulty or missing equipment
Groundwater monitoring
Nonlisted or restricted waste activities
Unauthorized discharge/disposal
Hazardous waste treatment, storage or disposal
Spills, releases, etc. not reported
Not in accordance with closure plans
Spill, leak, or discharge contamination
Leak or spill from container or UST
Underground storage tank
Failure to respond
Average
Proposed
Penalty
$64,248
$18,079
$7,306
$5,458
$7,148
$8,661
$148,498
$59,589
$10,341
$13,464
$18,761
$49,500
$109,075
$35,140
$20,533
$17,500
NA
$500
$5,625
NA
NA
$18,750
Appendix B contains a summary of all second and third level violations.
NOTE: NA = no average proposed penalty amount could be determined.
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As shown in Figure 4, storage and accumulation issues represented the largest single second-
level violation category (135 violations-19%), followed by operations and maintenance failures
(133 violations-19%), labeling (87 violations-12%), security and safety (68 violations--10%),
and records submissions (58 violations—8%). Collectively, these five categories represent nearly
69% of the 701 violations recorded. The remaining 220 violations fell into the 17 other
categories shown in Table 3 above.
Figure 4. Frequency of 701 Violations
by Second Level Category (with code)
General O&M failures (45) 133^_
Storage and accumulation
^^^^ violations (44) 135
Labeling deficiencies(43) 87
Security and safety (72) 68
Records submissions (42) 58 ^|g _^- 'M 0{her£ ;, -
Breakdown by Third-Level Violation Category
A third-level breakdown, in Figures 5-9, of the five second-level violation categories in Figure 4
offers the most detailed look at specific deficiencies noted during compliance inspections.
Figure 5 provides a breakdown of the 135 storage and accumulation violations (code 44). As
shown in Figure 5, the most common storage and accumulation violations were: 1) failure to
indicate start dates on containers; 2) storage beyond permitted time limits and/or volumes; 3)
operating without an interim status permit; and 4) either storing incompatible wastes or failing to
consider waste incompatibilities. Refer to Appendix A for a full description of all codes.
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Figure 5. Frequency of Third Level Storage and
Accumulation Violations (code 44)
Time limits(44c) 30
Volume limits(44b) 17
Start dates(44d) 53
Improper storage(44k) 1
SAA control(44h) 2
SAA dates(44i) 3
Unauthorized storage(44g) 7
Incompatibility (44e/j) 10
No interim status(44f) 12
Figure 6 provides a breakdown for the 133 general O&M failures violations (code 45). As
shown in Figure 6, the most common operation and maintenance violations included: 1) failure
to make HW determinations; 2) failure to close HW containers; 3) lack of adequate isle space in
storage areas; 4) use of defective storage containers; 5) exercising poor or little control at
landfills or accumulation points; and 6) failure to containerize HW.
Figure 6. Frequency of Third Level Operation and
Maintenance Violations (code 45)
Open containers(45c) 43
HW determination(45g) 57
LLost HW(45h) 1
Improper O&M(45j) 2
HW containment(45i) 3
.F/AP control(45d) 5
Container defect (45b) 11
Aisle space(45e) 11
10
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Figure 7 provides a breakdown of frequency of the 87 labeling deficiencies (code 43). As
shown, the principle deficiency noted here was failure to label/improperly labeled containers.
Figure 7. Frequency of Third Level Labeling
Violations (code 43)
Failure to label containers(43b) 86
Illegible labels(43e) 1
Figure 8 presents a breakdown of the 68 security and safety violations (code 72). The principal
deficiencies noted in the security and safety area were: 1) failure to provide or maintain
emergency response equipment; 2) failure to conduct operations in a way that minimizes fire or
HW releases; 3) failure to post HW management areas; and 4) failure to provide personal
protective equipment.
Figure 8. Frequency of Third Level Security and
Safety Violations (code 72)
Emergency response equiprnent(72c) 31
No HAZMIN(72h) 19
Contingency plan(72d) 1
Poor security[72i) 1
Safety precautions(72j) 1
'Lack of aisle space(72e) 4
NoPPE(72b) 5
HWMA not posted(72f) 6
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Lastly, Figure 9 provides a breakdown of the 58 record submissions violations (code 42).
In the records submissions category in Figure 9, areas of concern include: 1) failure to
maintain or provide records; 2) inspection logs that are inadequate or missing; 3) inadequate
training records; 4) failure to obtain or maintain LDR certifications; and 5) errors in the
maintenance and/or submission of operating records or files.
Figure 9. Frequency of Third Level Record
Submission Violations (code 42)
Records maintenanoe(42h) 25
Inspection logs(42e) 19
Martifests(42b) 1
OB/OD records(42d) 1
Operating records(42a) 2
LDR certificafons(42e) 3
Training records(42g) 7
Summary of Ten Most Frequent Third-Level Violations and Penalties
Table 4 provides the ten most frequent third-level violations cited in both Federal and State
orders along with an average proposed penalty. Failure to label or having improperly labeled
containers was the most frequent third-level violation (87 occurrences) and was assessed an
average proposed penalty of $7,306. The third most common violation, failing to indicate
start dates on containers (53 occurrences), carried the highest average proposed penalty of the
ten most frequent third-level violations at $95,794. However, the highest average proposed
penalty of any violation was $217,495 for failure to develop/implement groundwater
monitoring programs (code 22b), which had only two occurrences. Appendix B contains a
summary of all violations at the second and third level with average proposed penalties.
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Table 4. Ten most frequent third level violations and average proposed penalty
llfedbMft
Violation
/oaqmr,'
43b
45g
44d
45c
72c
44c
42h
47b
72h
42e
&e$m£*$
86
57
53
43
31
30
25
20
19
19
Beaacipti&tt
/-'"'" '
Failure to label or improperly labeled containers
Incomplete or failure to make HW determination
Failure to indicate accumulation/storage start dates on containers
Failure to close hazardous waste containers
Failure to provide/maintain emergency response equipment
Storage beyond permitted time limits
Failure to maintain or provide records
Failure to prepare/improper preparation of manifest
Failure to operate in a way mat mmimi7.es fire or HW releases
Inspection logs incomplete
.* ;
Areragr
Proposed
Penalty
$7,306
$27,871
$95,794
$4,409
$3,408
$28,061
$13,414
$10,065
$6,239
$2,979
Appendix B contains a summary of all second and third level violations.
Violation^ "d Larest Averae Penalties
Figures 10 and 11 summarize the five largest average proposed penalty amounts for
and third-level violation categories, respectively.
the second
Figure 10. Five Largest Average Proposed Penalty
Amounts for Second Level Violation Categories
Violation category (second level)
Unpermitted activity (41)
Monitoring errors (22)
Storage/accum issues (44)
Forms, documents (73)
Faulty or missing equip 0
50,000 100,000 150,000 200,000
Average penalty
Includes Federal and State orders.
13
-------
For the second level, Figure 10 above, they are: 1) unpermitted and unauthorized activity
($148,498); 2) monitoring errors ($109,075); 3) storage and accumulation issues ($64,248); 4)
inadequate/incomplete forms, documents, plans, manuals, procedures ($59,589); and 5)
inoperative, poorly designated or nonexistent equipment needed to meet permit condition
($49,500).
Figure 11. Five Largest Average Proposed Penalty Amounts
for Third Level Violation Categories
Violation category (third level)
GWM program(22b)
Unpermitted activities(41a)
Interim status permit(41c)
Closure ptans(73d)
Container start dates (44d)
50.000 100,000 150.000 200,000 250,000 300,000
Average penalty
Includes Federal and State orders.
For the third level, Figure 11, they are: 1) failure to develop/implement groundwater
monitoring program capable of determining facility's impact on quality of groundwater
($217,495); 2) unpermitted activities of equipment within a permitted program ($175,536); 3)
treatment, storage, disposal/transport of hazardous waste without a permit of interim status
($169,720); 4) inadequate/incomplete closure and post closure plans ($125, 725); and 5)
failure to indicate accumulation or storage start dates on containers ($111,347).
14
-------
ADMINISTRATIVE ORDER SETTLEMENT ANALYSIS
Average Negotiation Time to Final Settlement
Of the 76 State orders included in the study, a total of 42 (55%) were settled at the conclusion of
this study. Of the 29 Federal orders, a total of 13 (45%) were settled. The average amount of
time elapsed from issuance of a proposed AO to final AO was 369 days for Federal orders as
compared to 196 days for State orders (a nearly 2:1 ratio). One possible factor to consider for the
difference in settlement times is that Administrative settlement procedures vary for Federal vs.
State and between States.
Average Penalties Proposed and Final (EPA Regional Perspective)
Even though there were fewer Federal orders than State orders (29 AOs vs. 76 AOs), the average
proposed penalty was consistently higher for Federal orders; $321,921 per Federal order versus
$54,664 per State order. Figure 12 shows a breakdown by EPA Region of average proposed
penalty amounts of Federal vs. State orders. As shown, within each Region, Federal orders had
higher average proposed penalties than States.
Figure 12. Average Proposed Penalty Amounts
Federal vs. State (all orders by EPA Region)
Average penalty
$1,000,000 ,
$800,000 i
3600,000
5400,000
$200,000
0
r»
'Region
Federal!!
Slate •
1
W.234
27.000
II
47,500
10,603
III
115,586
11.666
IV
50.250
11.535
V
56.637
8.722
M
785750
171.574
Ml
201,640
Mil
-
10.000
IX
322.732
31,582
X
878.064
61.891
Includes orders under negotiation.
Federal average proposed penalty amounts per AO were consistently higher
than those proposed by the States.
15
-------
Figure 13. Average Federal Penalty Amounts
Proposed vs. Final (by EPA Region)
Average penalty
-------
Figure 14.
Proj
Average p
$300, 000
$250,000
$203,000
$150,000
$100,000
$50,000
0
Region
Proposed I
Final F
Average State Penalty Amounts
josed vs. Final (by Region)
enatty
~^l
^Bz~
I 1
B 1 •» m> ,
IV VI VIII IX
11,479 278,116 20,000 17,800
a 357 1ia781 10,905 10,672
Includes only proposed amounts from final State orders.
Only those Regions shown had final State orders.
...as were State.
Figure 14 shows the extent to which penalties were mitigated for State orders. Again, amounts
do not include State-negotiated SEPs (three State AOs contained SEP data, which averaged
$20,245 per order). The mitigation percentages ranged from a high of 57.3% for States in
Region VI to a low of 27.2% in Region IV.
17
-------
Figure 15. Average Federal Penalty Amounts
Proposed vs. Final (by Agency)
Average penalty
$250,000 i
$200,000
$150,000
$100, OX
$50,000
0
Includes only proposed amounts from final Federal orders.
Only those agencies shown had final Federal orders.
"Agreed to SEPs totaling $259,254.
The Army's average penalty was mitigated 69% for Federal orders; Air Force was mitigated
39%; and Navy 43%. The USCG performed SEPs totaling $259,254.
Average Penalties Proposed and Final (Federal Agency perspective)
Figures 15 and 16 summarize each Federal agency's penalty mitigation amounts. For Federal
AOs, Figure 15, only the Air Force, Army, Navy, and USCG had final orders in place at the time
of completion of this study. Of those four, the Army's penalty was mitigated 69% at settlement,
the Navy's 43%, and the Air Force's 39%. The USCG agreed to execute SEPs at an estimated
cost of $259,254.
18
-------
Figu
Average [
5300,000 r
«Ott"l nnr) L
$z>m mn
$150,000
$100,000
$50,000
Agency
Propose^
Final C
re 16. Average State Penalty Amounts
Proposed vs. Final (by Agency)
>enalty
1 I
1 1
USAF Army DLA DoE Dol U!
12.028 18.98! aOOO 242.510 2,700 80
7,280 15.98< a 000 105,520 2. 125 42
1
>MC NASA Navy USDA
500 5,600 14,438 20,500
000 5,600 6,669 10,000)
Includes only those agencies with final State orders.
Includes only proposed almounts from final State orders.
At the State level, in general, the smaller proposed penalty assessments were not mitigated to
the same extent as larger proposed penalties
For State AOs, Figure 16, penalty mitigation percentages ranged from a low of zero for DLA and
NASA to a high of 56% for the DoE. In general, the smaller the amount of the original penalty,
the smaller the percent mitigation in the final orders.
Supplemental Environmental Projects (SEPs)
It should also be noted that, in some instances, negotiated settlements can actually result in
substantially more resources being applied for environmental projects through the use of SEPs.
SEPs are projects that are above and beyond those required to come into compliance for cited
violations and that are not already required by law or regulation. Seven AOs, discussed below,
contained SEPs as a mitigation factor for penalties. Four Federal orders contained SEPs valued
at $2,087,869. Three State AOs contained SEPs valued at a total of $60,736.
In EPA Order 9-94-0005, the U.S. Army's Schofield Barracks, Hawaii was cited in 1994 with 13
separate violations and a proposed penalty of $543,900. That amount was later reduced to
$77,347 at settlement; but at the same time, the settlement included a commitment by the Army
to undertake four SEPs that totaled $1,245,135. Briefly they are: 1) a pollution prevention
19
-------
project to eliminate 10,000 pounds annually of hazardous spent solvent waste streams from parts
washers by using a non-hazardous solvent substitute (cost: $242,191); 2) a project to relocate
and replace materials at 115 hazardous waste satellite accumulation points and development of
Standard Operating Procedures specific to each accumulation point (cost: $109,825); 3) a project
to provide Environmental Compliance Officer's Training for 300 company units (almost 600
individuals) and on-going training for all military/civilian employees who work with hazardous
material/waste (1080 employees annually) (cost: $497,119) and; 4) implementation of a
Hazardous Substance Management System (HSMS) to track hazardous material from "cradle to
grave" (cost: $396,000). In other words, the negotiated settlement resulted in expenditures for
environmental projects worth more than 2.4 times the proposed penalty.
In another EPA Order 1-95-1053, the USCG Academy, CT agreed to perform two SEPs totaling
$259,254. The USCG Academy was originally cited in 1995 with 10 separate violations and a
proposed penalty of $171,809. The first SEP is a storage tank consolidation project (cost:
$132,992) involving the removal of two underground storage tanks (USTs - one 2,000 gal and
one 4,000 gal) and one above ground storage tank (AST- 500 gal), and replacing them with one
dual compartment AST which will serve as a central fueling station. The second SEP is to
design and construct a permanent concrete block "Less than 90 Day Accumulation" building for
hazardous and regulated waste accumulation to replace the existing building (cost: $126,262).
EPA Order 9-93-0007 for the Naval Air Facility-El Centre, CA contained two SEPs worth a
total of $283,480. The first project is to replace equipment currently used for cleaning and
degreasing at the facility's five automotive/equipment maintenance areas with six Recyclable
High-Velocity Water-Jet Parts Washers at a cost of $19,480. The new equipment utilizes
detergent and high-velocity water jets instead of solvents which has the potential to achieve a
90% reduction in hazardous waste generated from parts cleaning and 100% elimination of
solvents used in degreasing. The second project is to implement a Hazardous Waste
Minimization Program (cost: $264,000) at the El Centre facility. The goals of the program are
to: achieve a 25% reduction in hazardous waste generation; reduce by 40% the hazardous
material line item inventory; and centralize control of hazardous material in order to reduce
quantities stored at individual workspaces.
In EPA Order 93-H-0003, the Iowa Army Ammunition Plant (IAAP), Middletown, IA agreed to
perform a SEP totaling $300,000. The IAAP was cited in 1993 with 12 separate violations and a
proposed penalty of $201,640. The penalty was mitigated to $138,922, and the Army agreed to
undertake a SEP estimated to cost $300,000. The SEP will completely eliminate treated pink
water discharges from one plant production facility by recycling the water back to the explosive
melt-pour wash down operation in another plant production facility.
20
-------
Three State Orders contained SEPs. In State Order 9309054, Hill AFB, Utah, agreed to perform
one SEP totaling $18,190 in addition to a penalty of $10,905. The proposed penalty was
$20,000. The SEP project consisted of replacing eight hydro-cyclones with eight centrifugal
desludgers. The project will result in the consolidation of nine hazardous wates sites into one
and will also decrease the amount of hazardous waste produced by reducing the amount of water
in the sludge.
State Order NMHWA 93-06, Holloman AFB, NM agreed to perform two SEPs totaling $18,168
and no payment of a penalty. The proposed penalty amount was $16,725. One SEP is to
purchase and place in operation two mercury vapor light bulb crushers (cost: $4,000). The other
is to purchase and place in operation three large refrigerant (freon) recovery units (cost: $14,168).
State Order NMHWA 93-06, Sandia National Labs, NM agreed to perform one SEP totaling
$24,378 and no payment of a penalty. The proposed penalty was $2,720. The project consists of
developing and conducting training (using a formal presentation and videotape) on cadmium-
coated counterfeit bolts and waste disposal for local organizations (such as American Institute of
Architects and Associated General Contractors) where suspect bolts are a potential problem.
This training provides education to groups on safety issues associated with counterfeit bolts and
demonstrates the need for proper training for hazardous waste recognition and disposal.
DATA LIMITATIONS
Several data shortfall areas surfaced during the study. The principal areas include the following:
• State enforcement agencies do not routinely assign specific penalty/SEP information to
each corresponding violation in AOs as is presently done in the Federal AOs. Doing so
would allow a more complete and accurate analysis of State AOs. A total of only 373 of
709 violations in the 106 orders had a clear corresponding penalty amount.
• At the conclusion of this study, only 56 of 106 AOs had been settled. Therefore, the
analysis of the final penalties assessed is incomplete.
• This analysis does not permit drawing conclusions about specific root causes of
violations. Regulating agencies and facilities may be better able to focus their training
and compliance assistance programs with this type of information.
21
-------
SUMMARY
This study principally involved the collection and detailed review of RCRA Federal and State
proposed (and final orders when available) administrative orders levied against Federal
facilities from October 1992 through December 1995.
Major findings include the following:
• A total of 105 RCRA administrative orders were issued from October 1992 through
December 1995 at 80 Federal facilities representing 11 Federal agencies.
• 29 orders (28 percent) were issued by EPA Regions and 76 orders (72 percent) were
issued by State enforcement agencies.
• 77 Federal and State orders (73 percent) were issued against facilities located in EPA
Regions IV, VI, and IX.
• The average settlement time was 369 days for Federal orders and 196 days for State
orders.
• During the study period, EPA proposed a total of $9,335,722 in penalties and States a
total of $4,154,484.
• The average Federal proposed penalty was $321,921 per order. The average State
proposed penalty was $54,664. The combined average for proposed orders was
$128,478.
• In most instances, proposed penalties were mitigated in the final orders. However, the
smaller the initial proposed penalty, the more likely the final penalty would be the
same as the initial proposed penalty.
• Seven orders (three State and four Federal) included specific SEP costing data. The
Federal SEP total was $2,087,869 and the State SEP total was $60,736.
• A total of 701 individual violations were cited in the 105 orders. Of those cited, the
majority (481— 69 percent) fell into five broad categories: 1) storage and accumulation
issues (135 violations); 2) general operations and maintenance failures (133
violations); 3) labeling deficiencies (87 violations); 4) safety (68 violations); and,
5) records submissions (58 violations).
22
-------
The five most frequent specific violations were: 1) failure to label or improperly
labeled containers (86 violations); 2) incomplete or failure to make a hazardous waste
determination (57 violations); 3) failure to indicate accumulation or storage start dates
on containers (53 violations); 4) failure to close HW containers (43 violations); and,
5) failure to provide/maintain emergency response equipment (31 violations).
Of the 701 violations cited, 199 were at Army facilities, 149 at Air Force facilities,
133 at Department of Energy facilities, and 130 at Navy facilities. Seven other Federal
agencies were collectively cited for the remaining 90 violations.
23
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Appendix A
RCRA Finding Codes
-------
RCRA Finding Codes
Findings Codes First Level
If the event recorded is a case of ...
EXCEEDANCE: The facility permit, or regulations, establish dis-
charge limits. Those limits have been violated.
TECHNICAL WORK: Highly technical work performed by single-
function specialists in special facilities (e.g., analysis of samples)
has been performed improperly or not at all.
This does not address general operator work that is somewhat
technical in nature (e.g. taking samples): see OPERATIONS be-
low.
PERSONNEL: Personnel actions have not been taken or re-
corded, e.g., failure to certify, failure to train, etc.
This does not include errors by the personnel themselves; see
OPERATIONS below.
OPERATIONS: A failure to operate a facility in accordance with
requirements; human error is a factor in this category including
failures to conduct required training and take required samples.
Paperwork deficiency, failing to record events, is considered a
MANAGEMENT problem (see below). This assumes that the fa-
cility is capable of being operated in compliance; if not, see FA-
CILITIES PROBLEMS below.
SPILLS/LEAKS/DISCHARGES: Pollution incidents (even if con-
tained) that occur as a result of unauthorized and/or unpermitted
discharges.
Where a permit exists, but the level of discharge exceeds that al-
lowed, use EXCEEDANCE category one.
FACILITIES PROBLEMS: Because of improper or obsolete de-
sign, it is physically impossible for a facility to achieve compli-
ance as presently configured.
GENERAL MANAGEMENT: Cases where required procedures
are in place and generally followed, and facilities are capable of
performing, but because of inadequate supervision or manage-
ment, regulatory violations occur. These are principally problems
of failure to prepare, submit, or maintain required documents.
Note: Operating without a permit is an action, not a paperwork
deficiency, and would be considered an unauthorized discharge.
LEGAL OBLIGATIONS: This category is for failure to follow
compliance agreements, or other legally-binding orders. These
issues arise where an installation has an arrangement with a
regulator, or the courts, and fails to live up to it. Thus, operating
without a permit, although a violation of law, would be considered
an unauthorized discharge (see above); missing a construction
deadline, while not prohibited by law, would be a violation of an
agreement.
The first
code digit
is. . .
1-
2-
3-
4-
5-
6-
7-
8-
For definitions
of the second
digit, go to
Table . . .
A-1
A-2
A-3
A-4
A-5
A-6
A-7
A-8
A-1
-------
Table A-1
Findings Code Description for Exceedences
Level
1
2
Code
1-
11
12
13
14
15
16
17
18
19
Violation level category
EXCEEDANCES
Volatile organic com-
pounds (VOCs)
Visible
SDWA and drinking water
standards
Required notifications
Inadequate levels of ...
NPDES and pretreatment
limits
Emission limits, fuel use,
miscellaneous
Unauthorized use of ...
Unreported exceedances
Violation level description
violation of permit conditions or regulation/statute limiting
VOC emissions.
Violation of opacity limits in stationary source exhaust emis-
sions.
Violations of primary drinking water standard, maximum con-
taminant levels (MCLs).
Failure to provide exceedance notifications to the public or
regulatory agency where required by permit or
regulation/statute.
Failure to maintain mandated chemical concentrations in such
facilities as public drinking water systems. This category also
includes cases of excessive levels where the requirement es-
tablishes an upper limit as well as a lower limit.
Violations of NPDES permit conditions of pretreatment permit
requirements.
Violation of contaminant level emission limits established by
permit or regulation other than those already noted in this sec-
tion.
Utilization of surface coatings, thinners, etc. prohibited by per-
mit or regulation.
Failure to report discharge/emission exceedance to specified
regulatory agency as required per permit or regulation.
A-2
-------
Table A-2
Finding Code Description for Technical Work
Level
1
2
3
Code
2-
21
22
22a
22b
22c
22d
22e
violation level category
TECHNICAL WORK
Sampling and analysis
Monitoring errors/failures
Groundwater monitoring
Underground storage tanks (USTs)
Violation level description
Failure to perform sampling, analysis, and monitoring in accordance
with prescribed procedures or permit criteria.
Failure to comply with monitoring protocol.
Failure to develop/implement groundwater monitoring program ca-
pable of determining facility's impact on quality of groundwater.
Failure to determine rate and extent of migration of HW in ground-
water.
Inadequate groundwater monitoring and sampling.
Failure to property monitor underground storage tanks.
A-3
-------
Table A-3
Code Description for Personnel Issues
Level
1
2
Code
3-
31
32
33
34
35
Violation level category
PERSONNEL ISSUES
Uncertified Personnel
Inadequate Supervision
Certification
Training: inadequate/not
done
Operator training
(not environmental staff)
Inadequate number
of personnel
Violation level description
Failure to use personnel certified for specific functions as required by
regulatory agencies.
Failure to use personnel certified for specific functions as required by
regulatory agencies. Inadequate certification records should be coded
42.
Failure to have properly certified supervision on site for specified opera-
tions, e.g. remediation, wastewater treatment operations supervision
(normally is at least one level of certification higher than supervised per-
sonnel operating the wastewater treatment plant).
Failure to train environmental personnel in the performance of their du-
ties as specified by Federal/state/local requirements. This reason code
also includes inadequate training, or failure to conduct annual refresher
training. Lack of training records should use code 42; failure to have
certification training, resulting in uncertified personnel, should use code
31.
Failure to train personnel outside of environmental staff organization.
This may include Defense Realization and Marketing Office or other
personnel handling hazardous wastes or Directorate of Engineering and
Housing personnel in waste or water treatment plants, landfills, etc.
Failure to provide personnel in sufficient quantity so as to comply with
permit conditions for an operation such as a sanitary landfill. State regu-
lations may also set personnel requirements for other operations subject
to environmental regulation.
A-4
-------
Table A-4
Code Description for Operational Deficiencies
Level
1
2
3
2
3
2
3
Code
4-
41
41 a
41 b
41c
41 d
42
42a
42b
42c
42d
42e
42f
42g
42h
43
43a
43b
43c
43d
43e
43f
43g
43h
43i
Violation level category
OPERATIONS
Unpermitted/unauthorized
activity
Record submissions
(inc or late)
Labeling deficiencies
Placard deficiencies
violation level description
Unpermitted activities or equipment within a permitted program.
Noncompliance with permit.
TSD/transport of HW without permit or interim status.
Failure to obtain permit/authorization.
Violations concerning operating records, files, etc., not maintained in ac-
cordance with regulations, includes incomplete/ late submittals.
Maintaining manifest copies.
Land disposal restriction (LDR) certifications/notifications.
Operating records of open burning/open detonation and other TSD op-
erations.
Inspection logs.
Discharge monitoring reports (DMRs).
Inadequate training records.
Failure to maintain or provide records.
General violations of regulations requiring labeling and placarding.
Failure to label or improperly labeled containers.
Improper signage in storage areas and facility boundaries.
Failure to label or improperly labeled fill pipes.
Hazardous waste labels illegible.
Also included in this category are placard deficiencies for vehicles trans-
porting hazardous waste/materials.
Failure to label.
Improper or inaccurate labeling.
Illegible labeling.
No placards on hazardous waste transport vehicles .
A-5
-------
Table A-4
Code Description for Operational Deficiencies (Continued)
Level
2
3
2
3
2
Code
44
44a
44b
44c
44d
44e
44f
44g
44h
44i
44j
44k
45
45a
45b
45c
45d
45e
45f
45g
45h
45i
45j
46
Violation level category
Storage and accumulation
issues
Operational & Maintnence
(O&M) failures
Faulty or missing equip-
ment
Violation level description
General violations related to storage and/or accumulation of HW.
Storage beyond permitted volume.
Storage beyond permitted time limits.
Failure to indicate accumulation or storage start dates on containers
Storage not lAWrecognized standards for incompatibility.
Storage of HW without interim status or permit
Storage of HW in areas not identified by permit
Failure to properly locate/control SAAs.
Failure to property date containers in SAAs.
Failure to adequately consider HW incompatibilities.
Improper/careless HW storage.
General violations of an operational and maintenance nature.
Use of defective containers.
Failure to close hazardous waste (HW) containers .
Poor or little control (landfill, accumulation point etc.).
Lack of proper aisle space in storage areas .
Lack of maintenance of pollution control equipment .
Incomplete or failure to make HW determination.
Hazardous Waste loss/missing.
Failure to containerize waste .
Improper O&M of containment facility.
This code is designated for violations resulting from inoperative, poorly
designated, or nonexistent equipment needed to meet permit conditions
and regulatory requirements, or to prevent releases of pollutants.
A-6
-------
Table A-4
Code Description for Operational Deficiencies (Continued)
Level
Code
Violation level category
Violation level description
47
Manifest/transport prob-
lems, LDR certification
47a
47b
47c
47d
47e
47f
47g
47h
47i
General violations where the manifest and/or transportation of H.W.'s is
not in accordance with regulations.
Failure to prepare/ improper/illegible preparation of the manifest.
Manifest discrepancies.
Including LDR certification requirements.
Transport violations.
Notification failure of treatment standards.
LOR notification failure.
Failure to obtain date and/or number of manifest.
Untimely submittal of manifest
48a
48b
48c
48d
48e
48f
48g
Nonlisted waste activities
Restricted waste activities
General HW stream activities such as generation, storage, and treatment
that do not appear on:
The installation permit
Notification of hazardous waste activity forms.
Permit applications.
Failure to properly identify and treat restricted wastes as required by
regulations.
Failure to submit/retain notification for restricted wastes shipped off-site
Failure to mark accumulation start date on restricted waste containers.
49
Inspections/engineering
certification
49a
49b
49c
General inspection/certification violations.
Failure to perform, or inadequate inspections required in permits or by
Federal/state/local regulations.
Failure to obtain engineering certification of structural integrity or proper
system installation prior to use of certain waste management units, such
as tanks.
A-7
-------
Table A-5
Code Description of Findings for Spills, Leaks, and Discharges
Level
1
2
3
2
2
3
2
3
2
3
2
Code
5-
51
51 a
51 b
51 c
52
53
53a
53b
53c
53d
54
54a
54b
54c
54d
55
55a
55b
56
Violation level category
SPILLS/LEAKS and
DISCHARGES
Unauthorized
discharge/disposal
Leak/spill from
container/UST
Bypass or overflow
Spill, leak or discharge
contamination
Procedural error causing
spill or pollution
Spills, releases, etc. not
reported
Violation level description
The events classified under these codes should be a significant departure
from permitted standards.
General unauthorized discharge or disposal violatons.
Discharges to "waters of the U.S." without a permit
Failure to properly dispose of materials.
Note: Do not include unauthorized emissions from point sources in this
category, see code 41. This code refers to an unpermitted program, or
one where a specific discharge occurred. Code 41 applies to unpermited
specific activities or equipment within a generally permitted program.
Leaks, spills, or discharges of hazardous substances from drums, USTs,
or other storage vessels into the soil, surface water, or groundwater.
General violations where the volume of waste overloads the containment
system.
Bypass of wastewater or industrial waste treatment operations.
Spills resulting from tank overflow.
Temporary failures of equipment that result in excessive discharges for a
short period.
General spill, leak, or discharge violations.
Inadequate spill cleanup or remediation.
Failure to respond to spills resulting in contamination of soil and ground-
water.
Failure to immediately dispose of HW release wastes.
Gendfjl violations resulting in soil and/or water contamination.
Open burning unit operational procedures that fail to prevent contaminant
release into soil or groundwater.
This violation code refers to spills, releases, etc., that are not reported in a
timely manner as defined by regulation.
A-8
-------
Table A-6
Code Description for Findings of Facilities Problems
Level
1
2
3
2
3
2
3
2
3
Code
6-
61
61 a
61 b
61c
61 d
61e
62
62a
62b
62c
62d
62e
63
63a
63b
63c
63d
63e
63f
63g
64
64a
64b
64c
64d
64e
Violation Level category
FACILITY PROBLEMS
Facility design or capabilities
Monitoring/detection/
control systems
Hazardous waste treatment,
storage, or disposal
Underground storage tanks
Violation Level description
General violations resulting from design deficiencies for a variety of in-
stallation structures, systems, or resources.
Inadequate cross-connection or back flow prevention systems.
Inadequate supply of potable water.
Inefficient sewage treatment systems.
Any other cases of inadequate capability, capacity, or containment as a
result of the facility design.
Note: Hazardous waste facilities are covered separately under code 63.
General monitoring/detection/control systems violations.
Failure to properly design and install groundwater monitoring wells.
Land management activities that do not allow for erosion control meas-
ures.
Inadequate tank level monitoring system.
Failure to install interstitial leak detection system.
General HW TSD facilities violations.
Lack of secondary containment.
Structural flaws in storage areas.
Lack of runoff control for waste piles.
Defects in impoundment liners or berms.
Failure to install leachate collection system or liner.
Failure to protect HW from the elements.
General UST design or operational capability violations.
Inadequate cathodic protection.
Lack of overfill protection.
Failure to provide vapor Phase 1 or Phase II recovery.
Failure to provide pressure testing.
Ancillary devices, such as lead detection systems in interstitial spaces
should be coded under item 62. Code 64 pertains primarily to as-built or
modified structural items relating to corrosion protection, tank tightness,
etc.
A-9
-------
Table A-7
Code Description for Findings of Facilities Problems
Level
Code
Violation level category
Violation level description
GENERAL MANAGEMENT
71
Reports
71 a
71 b
71c
71 d
71 e
71f
719
71 h
71 i
71j
71k
General failures to submit required reports.
Consistently inadequate DMRs, or outright failure to submit DMRs, indi-
cate management deficiencies. Note: occasional late or incomplete
DMRs belong in code 42
Failure to comply with public notification requirements.
Failure to file miscellaneous reports.
Annual hazardous waste assessment reports.
Reports related to groundwater monitoring operations that are part of
CERCLA or RCRA corrective action.
Failure to submit notice of non-compliance.
Failure to sign required reports.
Failure to file manifest reports.
Failure to file exception reports for manifests.
Failure to submit HW release report in timely manner.
72
Security and Safety
72a
72b
72c
72d
72e
72f
72g
72h
72i
72J
General security and safety violations.
Failure to provide personal protection equipment.
Failure to maintain/provide equipment to be utilized in response to
emergencies.
Providing for employee safety and health as detailed in an installation
contingency plan.
Inadequate aisle space for egress (see code 45).
Failure to post hazardous waste management areas.
Failure to coordinate emergency response plans with local agencies
such as police and fire departments.
Failure to operate in a way that minimizes fire or HW release.
Failure to provide adequate security procedures.
Failure to take safety precautions.
A-10
-------
Table A-7
Code Description for Findings of Facilities Problems (Continued)
Level
2
3
2
2
2
Code
73
73a
73b
73c
73d
73e
73f
73g
73h
73i
73j
73k
731
73m
74
75
76
Violation level category
Forms, documents, plans,
manuals, procedures, etc.
Inadequate/incomplete
Fees not paid
Failure to respond to
regulatory authority notice
Failure to respond
Violation level description
General failure to submit timely or adequate documentation, plans, proce-
dures, etc.
Waste analysis plans.
Contingency plans.
Closure and post closure plans.
Parts "A" and "B" permit application.
Financial assurance documentation.
Groundwater monitoring/sampling plans.
Asbestos-containing material project notices.
Waste disposal documentation.
Spill prevention and control contingency plans.
Pollution Prevention Facility Plan.
Required Certifications.
Other documents required in order to be allowed to have a permitted pro-
gram but not of themselves essential to operation of environmental activi-
ties. Operating records/plans violations are not to be recorded here (see
code 42).
This reason code identifies violations that are issued solely to document
the failure to pay such as those required for permits, registration fees
(USTs), or HW assessment fees.
Receipt of a violation due to lack of response to a prior violation notice that
required action on the installation's part within a specified period of time.
Information request
A-ll
-------
Table A-8
Code Description for Findings of Facilities Problems
Level
1
2
Code
8-
81
82
83
84
85
86
violation level category
LEGAL AGREEMENTS (OTHER
LEGAL OBLIGATIONS, PERMITS,
AND PLAN REQUIREMENTS)
Not in accordance with compli-
ance agreement
Late in achieving compliance
agreement milestone
Not in accordance with closure
plans
Late with closure milestones
Not in accordance with
permit/plan/schedule/other legal
requirements
Late with permit/plan/schedule/
other milestones
Violation level description
This code applies to violations that result from failure to correct
a violation in accordance with the dictates of a compliance
agreement
This code applies to violations that result from failure to achieve
a milestone per compliance agreement requirements.
Violations of this type occur when closure of specific operational
units and structures is not completed according to closure plan
specifications or requirements.
Violations of this type occur when closure of specified opera-
tional units and structures is not completed in a timely manner in
accordance with milestones in a closure plan.
Violations of this type occur when activities are conducted in a
manner not in accordance with a permit plan, or schedule
agreed to by an installation and regulatory agency. Note: Ex-
ceedances and procedural violations are covered under codes
1 0 and 40; this code addresses failure to act as agreed by a le-
gal document other than a "compliance agreement'
Violations of this type occur when projects are not achieved in a
timely manner in accordance with milestones in a permit, plan,
or schedule agreed to by an installation and regulatory agency.
A-12
-------
Appendix B
Summary of RCRA Violations by Category Level
Breakdown by Major Violation Category (2nd level) B-l
Breakdown by Detailed Violation Category (3rd level)
Breakdown of Storage and Accumulation Violations (code 44) B-2
Breakdown of General O&M Failure Violations (code 45) B-3
Breakdown of Labeling Deficiency Violations (code 43) B-4
Breakdown of Security and Safety Violations (code 72) B-5
Breakdown of Record Submission Violations (code 42) B-6
Breakdown of Manifest and Transport Violations (code 47) B-7
Breakdown of Unpermitted and Unauthorized Activity Violations (code 41) B-8
Breakdown of Forms, Documents, Plans Violations (code 73) B-9
Breakdown of Reports Violations (code 71) B-10
Breakdown of Inspections/Engineering Certification Violations (code 49) . B-ll*
Breakdown of Training Violations (code 33) B-12
Breakdown of Faulty or Missing Equipment Violations (code 46) B-l3
Breakdown of Groundwater Monitoring Violations (code 22) B-14
Breakdown of Restricted Waste Activity Violations (code 48) B-l5
Breakdown of Unauthorized Discharge Violations (code 51) B-16
Breakdown of Hazardous Waste TSD Violations (code 63) B-l7
Breakdown of Spills and Releases Violations (code 56) B-l8
Breakdown of Closure Plan Violations (code 83) B-19
Breakdown of Spill/Leak/Discharge Contamination Violations (code 54) . B-20
Breakdown of Top 10 Detailed Violations by Category (3rd level) B-21
-------
BREAKDOWN OF VIOLATIONS BY MAJOR VIOLATION CATEGORY (2ND LEVEL)
VIOLATION CATEGORY
44
45
43
72
42
47 .
41
73
71
49
33
46
22
48
51
63
56
83
54
52
64
76
TOTAL
NUMBER OF VIOLATIONS
135
133
87
68
58
53
41
39
21
18
17
5
5
5
4
3
2
2
2
1
1
1
701
DESCRIPTION OF VIOLATION
Storage and accumulation issues
General O&M failures
Labeling deficiencies
Security and safety
Record submissions (incomplete or late)
Manifest and transport problems, LDR certification
Unpermitted and unauthorized activity
Forms, documents, plans, manuals, procedures - inadequate/incomplete
Reports
Inspections and engineering certification
Training: inadequate/not done
Faulty or missing equipment
Groundwater monitoring
Nonlisted and restricted waste activities
Unauthorized discharge/disposal
Hazardous waste treatment, storage or disposal
Spills, releases, etc. not reported
Not in accordance with closure plans
Spill.leak or discharge contamination
Leak/spill from container/UST
Underground storage tank
Failure to respond
AVG PEN
$64,248
$18,079
$7,306
$5,458
$7,148
$8,661
$148,498
$59,589
$10,341
$13,464
$18,761
$49,500
$109,075
$35,140
$20,533
$17,500
NA
$500
$5,625
NA
NA
$18,750
B-1
-------
BREAKDOWN OF STORAGE AND ACCUMULATION ISSUES (CODE 44x) (3RD LEVEL)
VIOLATION CATEGORY
44d
44c
44b
44f
44e
44g
44i
44h
44k
44j
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
53
30
17
12
9
7
3
2
1
1
135
DESCRIPTION OF VIOLATION
Failure to indicate accumulation or storage start dates on containers
Storage beyond permitted time limits
Storage beyond permitted volume
Storage of HW without interim status or permit
Storage not in accordance with recognized standards for incompatibility.
Storage of HW in areas not identified by permit
Failure to properly date containers in SAAs
Failure to properly locate/control SAAs
Improper/careless HW storage
Failure to consider HW incompatibility
AVG PEN
$95,794
$28,061
$6,908
$125,725
$6,500
$600
$7,500
$12,375
NA
$22,500
B-2
-------
BREAKDOWN OF GENERAL O&M FAILURES (CODE 45x) (3RD LEVEL)
VIOLATION CATEGORY
45g
45c
45e
45b
45d
45i
45}
45h
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
57
43
11
11
5
3
2
1
133
DESCRIPTION OF VIOLATION
Incomplete or failure to make HW determination
Failure to close hazardous waste (HW) containers
Lack of proper aisle space in storage areas
Use of defective containers
Poor or little control at landfill, accumulation point, etc.
Failure to containerize Hazardous Waste
Improper O&M of containment facility
Hazardous Waste loss/missing
AVG PEN
$27,871
$4,409
$6,510
$40,157
$3,450
$9,000
NA
NA
B-3
-------
BREAKDOWN OF LABELING DEFICIENCIES (CODE 43x) (3RD LEVEL)
VIOLATION CATEGORY
43b
43e
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
86
1
87
DESCRIPTION OF VIOLATION
Failure to label or inproperly labeled containers
Hazardous waste labels illegible
AVG PEN
$7,306
MA
B-4
-------
BREAKDOWN OF SECURITY AND SAFETY VIOLATIONS (CODE 72x) (3RD LEVEL)
VIOLATION CATEGORY
72c
72h
72f
72b
72e
72j
72i
72d
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
31
19
6
5
4
1
1
1
68
DESCRIPTION OF VIOLATION
Failure to provide/maintain equipment to be utilized in response to emergencies
Failure to operate in a way that minimizes fire or HW release
Failure to post hazardous waste management areas
Failure to provide personal protection equipment
Inadequate aisle space for egress
Failure to take safety precautions
Inadequate security procedures/measures
Providing for employee safety and health per installation contingency plan.
AVG PEN
$3,408
$6,239
$2,375
$5,322
$19,125
NA
$3,199
NA
B-5
-------
BREAKDOWN OF RECORD SUBMISSIONS VIOLATIONS (CODE 42x) (3RD LEVEL)
VIOLATION CATEGORY
42h
42e
42g
42c
42a
42d
42b
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
25
19
7
3
2
1
1
58
DESCRIPTION OF VIOLATION
Failure to maintain or provide records
Inspection logs
Inadequate training records
Land disposal restriction (LDR) certifications
Violations concerning operating records/files maintenance and submittals
Operating records of open burning/open detonation and other TSD operations
Maintaining manifest copies
AVG PEN
$13,414
$2,979
$9,108
NA
NA
NA
$1,200
B-6
-------
BREAKDOWN OF MANIFEST AND TRANSPORT VIOLATIONS (CODE 47x) (3RD LEVEL)
VIOLATION CATEGORY
47b
47g
47f
47d
47h
47e
47i
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
20
15
7
5
3
2
1
53
DESCRIPTION OF VIOLATION
Failure to prepare/improper/illegiable preparation of the manifest.
LDR notification failure
Notification failure of treatment standards
LDR certification requirements.
Failure to obtain date and/or number of manifest
Transport violations
Untimely submittal of manifests
AVG PEN
$10,065
$7,140
$4,867
$6,875
$2,875
$30,140
NA
B-7
-------
BREAKDOWN OF UNPERMITTED AND UNAUTHORIZED ACTIVITY VIOLATIONS (CODE 41 x) (3RD LEVEL)
VIOLATION CATEGORY
41 a
41c
41 b
41d
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
17
17
4
3
41
DESCRIPTION OF VIOLATION
Unpermitted activities, or equipment, within a permitted program
TSD of HW without permit or interim status
Noncompliance with permit conditions
Failure to obtain permit/authorization
AVG PEN
$175,536
$169,720
$17,500
$9,000
B-8
-------
BREAKDOWN OF FORMS, DOCUMENTS, PLANS VIOLATIONS (CODE 73x) (3RD LEVEL)
VIOLATION CATEGORY
73c
73b
73d
73m
731
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
17
9
9
3
1
39
DESCRIPTION OF VIOLATION
Contingency plans
Waste analysis plans
Closure and post closure plans
Other documents required in order to have a permitted program
Required certifications
AVG PEN
$35,378
$44,706
$111,347
NA
$2,251
B-9
-------
BREAKDOWN OF REPORTS VIOLATIONS (CODE 71 x) (3RD LEVEL)
VIOLATION CATEGORY
71j
71e
71 i
71h
71k
71 g
71d
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
9
4
2
2
2
1
1
21
DESCRIPTION OF VIOLATION
Failure to file exception reports
Failure to submit required annual hazardous waste assessment reports
Failure to file manifest reports
Failure to sign required reports
Failure to submit HW release report in timely manner
Failure to submit notice of non-compliance
Failure to submit required (miscellaneous) reports
AVG PEN
$ 25,267
$ 3,729
NA
$ 425
$ 9,500
$ 9,500
$ 300
B-10
-------
BREAKDOWN OF INSPECTIONS AND ENGINEERING CERTIFICATION VIOLATIONS (CODE 49x) (3RD LEVEL)
VIOLATION CATEGORY
49b
49c
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
16
2
18
DESCRIPTION OF VIOLATION
Failure to perform, or inadequate inspections required by permits/regulations.
Failure to obtain engineering certification of structural integrity/system installation
AVG PEN
$13,464
NA
B-11
-------
BREAKDOWN OF TRAINING VIOLATIONS (CODE 33) (2ND LEVEL)*
VIOLATION CATEGORY
33
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
17
17
* NOTE: There is no 3rd level for this violation category.
DESCRIPTION OF VIOLATION
Inadequate training or failure to train environmental staff per regulatory requirements
AVG PEN
$18,761
B-12
-------
BREAKDOWN OF FAULTY OR MISSING EQUIPMENT VIOLATIONS (CODE 46) (2ND LEVEL)*
VIOLATION CATEGORY
46
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
5
5
*NOTE: There is no 3rd level for this violation category.
DESCRIPTION OF VIOLATION
Violations resulting from inoperative, poorly designated, or nonexistent equipment
needed to meet permit conditions and regulatory requirements or to prevent
releases of pollutants into the environment
AVG PEN
$49,500
NA
NA
B-13
-------
BREAKDOWN OF GROUNDWATER MONITORING VIOLATIONS (CODE 22x) (3RD LEVEL)
VIOLATION CATEGORY
22b
22d
22c
22a
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
2
1
1
1
5
DESCRIPTION OF VIOLATION
Failure to develop/implement a groundwater monitoring program
Inadequate groundwater monitoring and/or sampling
Failure to determine rate and extent of migration of HW in groundwater
Failure to comply with monitoring protocol
AVG PEN
$217,495
$8,400
$91,786
$10,200
B-14
-------
BREAKDOWN OF RESTRICTED WASTE ACTIVITY VIOLATIONS (CODE 48x) (3RD LEVEL)
VIOLATION CATEGORY
48e
48c
48b
48f
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
2
1
1
1
5
DESCRIPTION OF VIOLATION
Failure to properly identify and treat restricted wastes as required by regulations
HW stream activities that do not appear on notification of HW activity forms
HW stream activities that do not appear on the installation permit
Failure to submit/retain notification for restricted waste
AVG PEN
$3,500
$95,420
$6,500
NA
B-15
-------
BREAKDOWN OF UNAUTHORIZED DISCHARGE VIOLATIONS (CODE 51 x) (3RD LEVEL)
VIOLATION CATEGORY
51b
51a
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
3
1
4
DESCRIPTION OF VIOLATION
Discharges to "waters of the U.S." without a permit
Discharges or disposal of regulated substances without proper permits
and in violation of Federal, state, or local regulations
AVG PEN
$20,533
NA
NA
B-16
-------
BREAKDOWN OF HAZARDOUS WASTE TSD VIOLATIONS (CODE 63x) <3RD LEVEL)
VIOLATION CATEGORY
63c
63b
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
2
1
3
DESCRIPTION OF VIOLATION
Design deficiencies for HW TSD facility - structural flaws in storage areas
Design deficiencies for HW TSD facility • lack of secondary containment
AVG PEN
$17,500
NA
B-17
-------
VIOLATION CATEGORY
56
TOTAL VIOLATIONS
BREAKDOWN OF SPILLS AND RELEASES VIOLATIONS (CODE 56) (2ND LEVELS
NUMBER OF VIOLATIONS
2
2
'NOTE: There is no 3rd level for this violation category.
DESCRIPTION OF VIOLATION
Spills, releases, etc., not reported in a timely manner as defined by regulation
AVG PEN
NA
B-18
-------
BREAKDOWN OF CLOSURE PLAN VIOLATIONS (CODE 83) (2ND LEVEL)*
VIOLATION CATEGORY
83
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
2
2
*NOTE: There is no 3rd level for this violation category.
DESCRIPTION OF VIOLATION
Violations resulting when closure of specific operational units and structures
not completed according to closure plan specifications or requirements
AVG PEN
$500
B-19
-------
BREAKDOWN OF SPILL, LEAK OR DISCHARGE CONTAMINATION VIOLATIONS (CODE 54x) (3RD LEVEL)
VIOLATION CATEGORY
54d
54b
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
1
1
2
DESCRIPTION OF VIOLATION
Failure to immediately dispose of HW release wastes
Inadequate spill cleanup or remediation
AVG PEN
$2,250
$9,000
B-20
-------
TOP 10 VIOLATIONS (3RD LEVEL)
VIOLATION CATEGORY
43b
45g
44d
45c
72c
44c
42h
47b
72h
42e
NUMBER OF VIOLATIONS
86
57
53
43
31
30
25
20
19
19
DESCRIPTION OF VIOLATION
Failure to label or improperly labeled containers
Incomplete or failure to make HW determination
Failure to indicate accumulation or storage start dates on containers
Failure to close hazardous waste containers
Failure to provide/maintain emergency response equipment
Storage beyond permitted time limits
Failure to maintain or provide records
Failure to prepare/improper/illegible preparation of manifest
Failure to operate in a way that minimizes fire or HW releases
Inspection logs
AVG PEN
$7,306
$27,871
$95,794
$4,409
$3,408
$28,061
$13,414
$10,065
$6,239
$2,979
B-21
-------
Appendix C
Summary of RCRA Administrative Orders by Agency
Air Force C-l
Air National Guard C-2
Army C-3
Coast Guard C-4
DLA C-5
DOE C-6
DOI C-7
Marine Corps C-8
NASA C-9
Navy C-10
USDA '. C-ll
-------
SUMMARY OF RCRA ADMINISTRATIVE ORDERS
AIR FORCE
AIR FORCE VIOLATION SUMMARY (2nd level)
VIOLATION CATEGORY
44
45
47
42
72
43
41
73
71
49
33
51
48
46
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
32
27
17
16
14
14
10
6
4
3
3
1
1
1
149
DESCRIPTION OF VIOLATION
Storage and accumulation issues
General O&M failures
Manifest and transport problems, LDR certification
Record submissions (incomplete or late)
Security and Safety
Labeling deficiencies
Unpermitted and unauthorized activity
Forms, documents, plans, manuals, procedures - inadequate/incomplete
Reports
Inspections and engineering certification
Training: inadequate/not done
Unauthorized discharge/disposal
Nonlisted waste activities
Faulty or missing equipment
AVG PEN
$48,516
$8,566
$8,611
$3,956
$5,659
$3,462
$106,760
$2,100
$2,450
$4,350
NA
$27,600
NA
NA
C-1
-------
Summary of RCRA Administrative Orders - Air Force
Facility
Andrews AFB
Andrews AFB
Andrews AFB
Andrews AFB
Andrews AFB
Beale AEB
Beale AFB
Beale AFB
Canon AFB
Canon AFB
Region State Dept Docket #
03 MD AF C-O-94-134
03 MD AF C-O-94-134
03 MD AF C-O-94-134
03 MD AF C-O-94-134
03 MD AF C-O-94-134
09 CA , AF FO 93/94-. ;
' , I*52 . '
09 CA AF FO 93/94-
1552
09 CA AF FO 93/94-
1552
06 ,NM AF NMHWA93-
' °5 '-,
06 NM AF NMHWA93-
05
Count Violation
Category
0 '
1 Storage and
accumulation issues
2 Faulty or missing
equipment
3 Security and Safely
4 Reports
, 0
1 Record submissions
(incomplete or late)
2 General O&M
failures
'0 " , ',
• . :
\ Storage and
accumulation issues
Violation Violation Issue
Description Penalty Date
$0 6/28/94
Storage of HW $0
without interim status
or permit
Violations resulting $0
from inoperative,
poorly designated, or
nonexistent equipment
needed to meet permit
conditions and
regulatory
requirements or to
prevent releases of
pollutants into the
environment.
Failure to operate in a $0
way that minimizes
fire or HW release
Failure to file $0
exception reports
, , $0' 12/9/93
Failure to maintain or $ 1 00
provide records
Failure to close $200
hazardous waste
(HW) containers
." , " $0 , 4/21/93
Storage beyond $ 1 3 ,702
permitted time limits
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
keg $5,000 $0 1994
$0 1994
$0 1994
$0 1994
$0 1994
Final $300 2/3/94 $100 1993
$0 1993
$0 1993
Neg $132,697 $0 1993
$0 1993
Issued
By
State
Stale
State
State
Stale
Stale
State
State
State
State
C-l-1
! RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility
Canon AFB
Canon AFB
Canon AFB
Canon AFB
Canon AFB
Canon AFB
Canon AFB
Canon AFB
Canon AFB
Region State Dept Docket #
06 NM AF NMHWA93-
05
06 NM AF NMHWA93-
05
06 NM AF NMHWA93-
05
06 NM AF NMHWA93-
05
06 NM AF NMHWA93-
05
06 NM AF NMHWA93-
05
06 NM AF NMHWA93-
05
06 NM AF NMHWA93-
05
06 NM AF NMHWA93-
05
Count Violation
Category
2 Security and Safety
3 Inspections and
engineering
certification
4 Security and Safety
5 Security and Safety
6 Security and Safety
7 Reports
8 General O&M
failures
9 Manifest and
transport problems,
LDR certification
Violation
Description
Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Failure to perform, or
inadequate inspections
required in permits or
by Federal/state/local
regulations.
Failure to operate in a
way that minimizes
fire or HW release
Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Failure to operate in a
way that minimizes
fire or HW release
Failure to sign
required reports
Incomplete or failure
to make HW
determination
Transport violations
10 Unpermitted and TSD of HW without
unauthorized activity permit or interim status
Violation Issue
Penalty Date
$8,800
$2,200
$2,200
$9,600
$4,400
$550
$30,140
$30,140
$30,140
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
C-l-2
RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility
Canon AFB
Charleston AFB
Charleston AFB
Charleston AFB
Eareckson AFB
Shemya
Eareckson AFB
Shemya
Eglin AFB
Eglin AFB
Eglin AFB
Eglin AFB
Region State Dept Docket #
06 NM AF NMHWA93-
05
04 ' ' , SC -. AF 93-30-HW
04 SC AF 93-30-HW
04 SC AF 93-30-HW
10 AK. AF IQ93-05-07-
10 AK AF 1093-05-07-
3008a
04 ; FL AF None-1 - - '
04 FL AF None-1
04 FL AF None-1
04 FL AF None-1
Count Violation
Category
1 1 Storage and
accumulation issues
o • . ;
1 Storage and
accumulation issues
2 Storage and
accumulation issues
' o ;,
1 Storage and
accumulation Issues
-0' :
1 Storage and
accumulation issues
2 Labeling deficiencies
3 Storage and
accumulation issues
Violation
Description
Failure to indicate
accumulation or
storage start dates on
containers
Failure to indicate
accumulation or
storage start dates on
containers
Storage beyond
permitted volume
Failure to indicate
accumulation or
storage start dates on
containers
Failure to indicate
accumulation or
storage start dates on
containers
Failure to label or
Improperly labeled
containers
Storage beyond
permitted volume
Violation Issue
Penalty Date
$825
$0 6/25/93
$0
$0
$0 6/24/93
$481,662 6/24/93
$0 6/13/94
$0
$0
$0
Status Total SEPS Settle Amount
Proposed Date Paid
Penalty
$0
Neg $7,250 $0
$0
$0
Neg $481,662 ' $0
Final $1,350 9/8/94 $1,350
$0
$0
$0
Year
Issued
1993
1993
1993
1993
1993
1993
1994
1994
1994
1994
Issued
By
State
State
State
Slate
EPA
EPA
State
State
State
State
C-l-3
RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility
Eglin AFB
EglinAFB
Eglin AFB
Eglin AFB
Eglin AFB
EglinAFB;
Eglin AFB
Eglin AFB
Eglin AFB
Eglin AFB
Region State Dept Docket* Count Violation Violation Violation Issue Status Total
Category Description Penalty Date Proposed
Penalty
04 FL AF None-1 4 Training: Inadequate training or $0
inadequate/not done failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
.,"•;,, 04- ' ;',F£!,';T;' AF/'-Non.6-2>' ,;„-„ '(;"°. ""' <'',.• ''• '•••'-'• '/',,' ' -,' '$0 7/16/93 Final $6>70°
04 FL AF None-2 1 Labeling deficiencies Failure to label or $0
improperly labeled
containers
04 FL AF None-2 2 General O&M Incomplete or failure $0
failures to make HW
determination
04 FL AF None-2 3 Storage and Storage beyond $0
accumulation Issues permitted time limits
•;*,,-. 04 '; <>&,,, ,.,.;AP, None4,, ,/;C/o:- ; ,;,, •-- , , .", j; - : , $011/12/93 Final $8,750
04 FL AF None-3 1 General O&M Incomplete or failure $0
failures to make HW
determination
04 FL AF None-3 2 Storage and Failure to indicate $0
accumulation Issues accumulation or
storage start dates on
containers
04 FL AF None-3 3 Labeling deficiencies Failure to label or $0
improperly labeled
containers
04 FL AF None-3 4 Storage and Storage beyond $0
accumulation issues permitted time limits
SEPS Settle Amount Year
Date Paid Issued
$0 1994
11/23/93 $10,500 1993
$0 1993
$0 1993
$0 1993
4/22/94 $8,750 1993
$0 1993
$0 1993
$0 1993
$0 1993
Issued
By
Stale
State
State
State
State
State
State
State
State
State
* RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility Region
EglinAFB 04
Eglin AFB 04
Eglin AFB 04
Ellsworth AFB "-. •' 08
Ellsworth AFB 08
Ellsworth AFB 08
Ellsworth AFB 08
GriffisAFB . 02
Griffis AFB 02
State Dept Docket # Count Violation
Category
FL AF None-3 5 General O&M
failures
FL AF None-3 6 Training:
inadequate/not done
FL AF None-3 7 Manifest and
transport problems,
LDR certification
' SO ',AF None ' ' "0,
SD AF None 1 Manifest and
transport problems,
LDR certification
SD AF None 2 Manifest and
transport problems,
LDR certification
Violation Violation Issue
Description Penalty Date
Failure to close $0
hazardous waste
(HW) containers
Inadequate training or $0
failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
Failure to $0
prepare/improper/illegi
ble preparation of the
manifest.
;',; - $0 3/15/93
Failure to $0
prepare/improper/illegi
ble preparation of the
manifest.
Notification failure of $0
treatment standards
SD AF None 3 Unpermitted and TSD of HW without $0
unauthorized activity permit or interim status
NY AF ^KCRA^3- 0 . ''•
. . '• .. / 0202,, ';_; __/;_, _ ; _ - ';,
NY AF 2-RCRA-93- 1 Security and Safety
0202
' • $0 1/13/93
' / '-. ' ' ' ' '
Providing for $0 1/13/93
employee safety and
health as detailed in an
installation
contingency plan.
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1993 State
$0 1993 State
$0 1993 Stale
Neg $0 $0 1993 Slate
$0 1993 State
$0 1993 State
$0 1993 State
final $0 7/19/93 $0 1993 EPA
1993 EPA
C-l-5
1 RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility
GriffisAFB
Griffls AFB
GriffisAFB
Griffis AFB
Griflis AFB
Griffis AFB
Griffis AFB
Griffis AFB
Region State Dept Docket #
02 NY AF 2-RCRA-93-
0202
02 NY AF 2-RCRA-93-
0202
02 NY AF 2-RCRA-93-
0202
02 NY AF 2-RCRA-93-
0202
02 NY AF 2-RCRA-93-
0202
02 NY AF 2-RCRA-93-
0202
02 NY AF 2-RCRA-93-
0202
02 NY AF 2-RCRA-93-
0202
Count
2
3
4
5
6
7
8
9
Violation Violation Violation Issue
Category Description Penalty Date
Restricted/Nonlisted Failure to properly $0 1/13/93
waste activities identify and treat
restricted wastes as
required by regulations
General O&M Use of defective $0 1/13/93
failures containers
Training: Inadequate training or $0 1/13/93
inadequate/not done failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
Manifest and LDR notification $0 1/13/93
transport problems, failure
LDR certification
Storage and Failure to indicate $0 1/13/93
accumulation issues accumulation or
storage start dates on
containers
Forms, documents, Waste analysis plans $0 1/13/93
plans, manuals,
procedures -
inadequate or
incomplete
Manifest and Failure to $0 1/13/93
transport problems, prepare/improper/illegi
LDR certification ble preparation of the
manifest.
Storage and Storage of HW in $0 1/13/93
accumulation issues areas not identified by
permit
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
1993
1993
1993
1993
1993
1993
1993
1993
Issued
By
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
C-l-6
: RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility
Giiffis AFB
Hill AFB , . ',
Hill AFB
Hill AFB
Hill AFB
Hill AFB
Hill AFB
HollmanAFB
Hollman AFB
Mollman AFB
Hollman AFB
Region State Dept Docket #
02 NY AF 2-RCRA-93-
0202
08 UT AF 9309054, ,
08 UT AF 9309054
08 UT AF 9309054
08 UT AF 9309054
08 UT AF 9309054
08 UT AF 9309054
06 NM AF KMHWA93-
,,,.'. 06
06 NM AF NMHWA93-
06
06 NM AF NMHWA93-
06
06 NM AF NMHWA93-
06
Count
10
0
1
2
3
4
5
0
1
2
3
Violation Violation
Category Description
Record submissions Failure to maintain or
(incomplete or late) provide records
General O&M Incomplete or failure
failures to make I IW
determination
Manifest and Transport violations
transport problems,
LDR certification
Record submissions Violations concerning
(incomplete or late) operating records,
flies, etc., not
maintained in
accordance with
regulations, to include
incomplete or late
submittals.
Unpermilted and Noncompliance with
unauthorized activity permit conditions
General O&M Hazardous Waste
failures loss/missing
General O&M Incomplete or failure
failures to make HW
determination
General O&M Incomplete or failure
failures to make HW
determination
General O&M Incomplete or failure
failures to make HW
determination
Violation Issue
Penalty Date
$0 1/13/93
$0 11/8/93
$0
$0 •
$0
$0
$0
$0 4/28/93
$3,740
$3,740
$3,740
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
1993 EPA
Final $20,000 $18,190 1/19/95 $10,905 1993 State
$0 1993 State
$0 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 State
Final $16,725 $18,168 4/18/94 $0 1993 State
$0 1993 State
$0 1993 Slate
$0 1993 Slate
C-l-7
* RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont)
Facility Region State Dept Docket # Count Violation
Category
Hollman AFB
Hollman AFB
Hollman AFB
Hulbert Field ~,
Hulbcrt Field
Hulbert Field
Hulbert Field
Hulbert Field
Hulbcrt Field
Hulbcrt Field
Klrtland AFB ,;,-•/'
06 NM AF NMHWA93- 4
06
06 NM AF NMHWA93- 5
06
06 NM AF NMHWA93- 6
06
,04 '• /PL ; AF None,, 0
04 FL AF None 1
04 FL AF None 2
04 FL AF None 3
04 FL AF None 4
04 FL AF None 5
04 FL AF None 6
"86\5;;'''"'<'ii'NM,/«:-,'"Al*' -i^JVtHWA9'4vsV'''0' '
' „". '''']/> "~ ,^::;:'^' >'.' ''• » ,,.07,! -"'J>-,' '•(• "•')--
General O&M
failures
Record submissions
(incomplete or late)
Storage and
accumulation issues
. .*..:,•. --
General O&M
failures
Storage and
accumulation issues
Labeling deficiencies
Storage and
accumulation issues
General O&M
failures
Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
- , • "' ''..-,'- "' , \ ", i
Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Description Penalty Date Proposed Date Paid Issued By
Penalty
Incomplete or failure $3,740
to make HW
determination
Inspection logs $550
Failure to indicate $1,215
accumulation or
storage start dates on
containers
$0 11/8/93 Final $4,250
Incomplete or failure $0
to make HW
determination
Failure to indicate $0
accumulation or
storage start dales on
containers
Failure to label or $0
improperly labeled
containers
Storage beyond $0
permitted volume
Failure to close $0
hazardous waste
(HW) containers
Contingency plans $0
K ,,:';',;' .,,. v ; ;. $0 5/17/94 Final $3,04«
$0 1993 State
$0 1993 State
$0 1993 State
6/20/94 $4,250 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
10/3/94 $3,046 1994 State
C-l-8
RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility Region State
Kirtland AFB 06 NM
Kirtland AFB ;, , ; 06 , : NM
• \ '> , -
Kirtland AFB 06 NM
LacklandAFB 0<5 ' TX, ,
Lackland AFB 06 TX
MacDill AFfl. 04 PL
MacDill AFB 04 FL
MacDill AFB 04 FL
MacDill AFB 04 FL
MacDill AFB 04 FL
MacDill AFB 04 FL
MacDill AFB 04 FL
Dept Docket # Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
AF NMHWA94-
07
' AF NMHWA95-
,,• 01 ',,,-,,
AF NMHWA95-
01
AF RCRA-r6-31l- ,
H '.. ,-- , ~_
AF RCRA-6-311-
H
AF None
AF None
AF None
AF None
AF None
AF None
AF None
1
0
1
0,
1
0
1
2
3
4
5
6
Penalty
Labeling deficiencies Failure to label or $3,046
improperly labeled
containers
,,'•', $0 2/14/94 , Neg $1,575
Storage and Storage beyond $1,575
accumulation issues permitted volume
'/'"'," ' V ' - , $0 6/30/93 Neg $346,500
'--,-'-"„ "<>,-, ','<•-
Unpermitted and TSD of HW without $346,500 6/30/93
unauthorized activity permit or interim status
$0 3/25/94 Final $0
Manifest and Failure to $0
transport problems, preparc/improper/illegi
LDR certification ble preparation of the
manifest.
Storage and Failure to indicate $0
accumulation issues accumulation or
storage start dates on
containers
Storage and Storage beyond $0
accumulation issues permitted volume
Labeling deficiencies Failure to label or $0
improperly labeled
containers
General O&M Incomplete or failure $0
failures to make HW
determination
Unpermitted and Unpermitted activities, $0
unauthorized activity or equipment, within a
permitted program
$0 1994 State
$0 1995 State
$0 1995 State
$0 1993 BPA
1993 EPA
4/22/94 $0 1994 State
$0 1994 State
$0 1994 State
$0 1994 Slate
$0 1994 State
$0 1994 Stale
$0 1994 State
C-l-9
* RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility Region State
MacPlu^je;^^;-^
MacDIlIAFB 04 FL
MacDill AFB 04 FL
MacDill AFB 04 FL
MacDill AFB 04 FL
March AFB, , ,'•''• 09 ' , /< ' .CA< "
March AFB 09 CA
March AFB 09 CA
March AFB 09 CA
McClelian APB g 1^$%$$^ &f$
McClcllan AFB 09 CA
McClelian AFB 09 CA
Dept Docket # Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
'^(W^fc
AF None-1
AF None-1
AF None-1
AF None-1
_ "M" HfCA 94/95., v
AF HWCA 94/95-
040
AF HWCA 94/95-
040
AF HWCA 94/95-
040
AF HWCA 93/94-
045
AF HWCA 93/94-
045
$>!
1
2
3
4
•*>/**
1
2
3
it
i
2
^?^;;- vr->- < '* , V , ', :,*.',
Unpermitted and Failure to obtain
unauthorized activity permit/authorization
Record submissions Inadequate training
(incomplete or late) records
General O&M Incomplete or failure
failures to make HW
determination
Storage and Storage of HW in
accumulation issues areas not identified by
permit
Storage and Storage of HW
accumulation issues without interim status
or permit
, $0 5/5/95,, Final $0
$0
$0
$0
$0
, '$0 9/22/94 Final $7,750-
$0
$0
$0
', , $6 8/16/94 : Final $73,500
$0
$0
6/20/95 $0 1995 State
$0 1995 State
$0 1995 State
$0 1995 State
$0 1995 State
5/25/95 $7,750 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
3/24/95 $40,000 1994 State
$0 1994 State
$0 1994 State
C-l-10
1 RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility
McClellan AFB
McClellanAFB
McClellan AFB
McClellan AFB
McClellan AFB
McClellanAFB
Ml Home AFB
Mt Home AFB
Mt Home AFB
Ml Home AFB
Mt Home AFB
Mt Home AFB
Region State Dept Docket #
09 CA AF HWCA 93/94-
045
09 CA AF HWCA 93/94-
045
09 CA AF HWCA 93/94-
045
09 CA AF HWCA 93/94-
045
09 CA AF HWCA 93/94-
045
09 CA AF HWCA 93/94-
045
10 ID AP , 3$M4t3-,,
10 ID AF 39-4413
10 ID AF 39-4413
10 ID AF 39-4413
10 ID AF 39^413
10 ID AF 39-4413
Count
3
4
5
6
7
8
0
1
2
3
4
5
Violation Violation
Category Description
Unpermitted and TSD of HW without
unauthorized activity permit or interim status
Storage and Storage beyond
accumulation issues permitted time limits
Labeling deficiencies Failure to label or
improperly labeled
containers
Record submissions Failure to maintain or
(incomplete or late) provide records
General O&M Use of defective
failures containers
General O&M Failure to close
failures hazardous waste
(HW) containers
Unpermitted and Unpermitted activities,
unauthorized activity or equipment, within a.
permitted program
Security and Safety Failure to operate in a
way that minimizes
fire or 1IW release
Record submissions Inspection logs
(incomplete or late)
Security and Safety Failure to operate in a
way that minimizes
fire or HW release
Manifest and Failure to
transport problems, prepare/improper/illegi
LDR certification We preparation of the
manifest.
Violation Issue
Penalty Date
$0
$0
$0
$0
$0
$0
$0 6/3/94,
$4,399
$3,199
$4,399
$1,200
$2,600
Status Total SEPS Settle Amount
Proposed Date Paid
Penalty
$0
$0
$0
$0
$0
$0
Neg $61,891 4/26/95 $0
$0
$0
$0
$0
$0
Year
Issued
1994
1994
1994
1994
1994
1994
1994
1994
1994
1994
1994
1994
Issued
By
State
State
State
State
State
State
State
State
State
State
State
State
C-l-11
* RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility Region State Dept Docket #
MtHomeAFB 10 ID AF 39-4413
MtHomcAFB 10 ID AF 39-4413
MtHomeAFB 10 ID AF 39-4413
MtHomeAFB 10 ID AF 39-4413
MtHomeAFB 10 ID AF 39-4413
MtHomeAFB 10 ID AF 39-4413
MtHomeAFB 10 ID AF 39-4413
MtHomeAFB 10 ID AF 39-4413
MtHomeAFB 10 ID AF 39-4413
MtHomeAFB 10 ID AF 39-4413
MtHomeAFB 10 ID AF 39-4413
Count Violation
Category
6 Security and Safety
7 Record submissions
(incomplete or late)
8 Security and Safety
9 Record submissions
(incomplete or late)
10 Record submissions
(incomplete or late)
11 General O&M
failures
12 Security and Safety
13 Manifest and
transport problems,
LDR certification
14 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
IS Record submissions
(incomplete or late)
16 Manifest and
transport problems,
LDR certification
Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Description Penalty Date Proposed Date Paid Issued By
Inadequate security
procedures/measures
Inspection logs
Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Inspection logs
Inspection logs
Incomplete or failure
to make HW
determination
Inadequate aisle space
for egress
Failure to
prepare/improper/illegi
ble preparation of the
manifest.
Waste analysis plans
Maintaining manifest
copies
LDR notification
failure
$3,199
$199
$10,000
$10,000
$4,399
$4,399
$10,000
$199
$1,200
$1,200
$599
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
C-l-12
* RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility Region State Dept Docket #
MtHomeAFB 10 ID AF 39-4413
MtHomeAFB 10 ID AF 39-4413
Patrick AFB - 04 R, AP None
Patrick AFB 04 FL AF None
Patrick AFB 04 FL AF None
Patrick AFB 04 FL AF None
Patrick AFB 04 FL AF None
ReescAFB , ,06 , tX - AF None
Reese AFB 06 TX AF None
Reese AFB 06 TX AF None
ReescAFB 06 TX AF None
Count Violation
Category
17 Storage and
accumulation issues
18 General O&M
failures
0 ' •
1 General O&M
failures
2 Storage and
accumulation issues
3 Labeling deficiencies
4 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
0
1 Unpermitted and
unauthorized activity
2 Storage and
accumulation issues
3 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
Violation Violation Issue Status Total SEPS
Description Penalty Date Proposed
Penalty
Storage beyond
permitted volume
Failure to close
hazardous waste
(HW) containers
Incomplete or failure
to make HW
determination
Failure to indicate
accumulation or
storage start dates on
containers
Failure to label or
improperly labeled
containers
Contingency plans
TSD of HW without
permit or interim status
Storage beyond
permitted time limits
Closure and post
closure plans
$600
$100
$0 8/10/94 Neg $16,599
$14,999
$300
$300
$1,000
$0 3/24/93 Neg $89,839
$46,000
$7,839
$8,400
Settle Amount Year Issued
Date Paid Issued By
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1993 Stale
$0 1993 Slate
$0 1993 State
$0 1993 State
C-l-13
* RCRA inspection took place before 10/92, therefore no penalties were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility Region State
Reese AFB 06 TX
Travis AF6;V /J'." ' '09'' «; ,cA/;'
' -, •'•?*• f?A' ''"•'; t'l^" ?•*/,'>'• >.",.
Travis AFB 09 CA
Travis AFB 09 CA
Travis AFB 09 CA
Travis AFB 09 CA
Travis AFB 09 CA
Travis AFB 09 CA
Travis AFB 09 CA
Travis AFB 09 CA
Dept Docket #
AF None
l-V'^.oofi-^-^;'
AF DO 93/94 2-
006
AF DO 93/94 2-
006
AF DO 93/94 2-
006
AF DO 93/94 2-
006
AF DO 93/94 2-
006
AF DO 93/94 2-
006
AF DO 93/94 2-
006
AF DO 93/94 2-
006
Count Violation
Category
4 Unauthorized
discharge/disposal
1 Labeling deficiencies
2 Labeling deficiencies
3 Storage and
accumulation issues
4 General O&M
failures
5 General O&M
failures
6 Storage and
accumulation issues
7 Manifest and
transport problems,
LDR certification
8 Manifest and
transport problems,
LDR certification
Violation Violation Issue
Description Penalty Date
Discharges to "waters $27,600
of the US." without a
permit
'" ;;'• '''','"-' ' ','•"„,'', $0, 8/11/93
Failure to label or $0 8/11/93
improperly labeled
containers
Failure to label or $0
improperly labeled
containers
Storage beyond $0
permitted time limits
Failure to close $0
hazardous waste
(HW) containers
Lack of proper aisle $0
space in storage areas
Storage not in $0
accordance with
recognized standards
for incompatibility.
Failure to $0
prepare/improper/illegl
ble preparation of the
manifest.
LDR certification $0
requirements.
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
$0 1993 State
Neg $15,900 $0 1993 Stale
Neg $15,900 $0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 Slate
$0 1993 State
C-l-14
* RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility Region
Travis AFB 09
Travis AFB 09
Travis AFB 09
Travis AFB 09
Travis AFB 09
Travis AFB 09
VandenbcrgAFB 09
Vandcnberg AFB 09
Vandenberg AFB 09
Vandenberg AFB 09
Vandcnberg AFB 09
State Dept Docket #
CA AF DO 93/94 2-
006
CA AF DO 93/94 2-
006
CA AF DO 93/94 2-
006
CA AF DO 93/94 2-
006
CA AF DO 93/94 2-
006
CA AF DO 93/94 2-
006
CA AF DO 93/94.
3009
CA AF DO 93/94-
3009
CA AF DO 93/94-
3009
CA AF DO 93/94-
3009
CA AF DO 93/94-
3009
Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
Penalty
9 Security and Safety Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
10 Storage and Storage not in
accumulation issues accordance with
recognized standards
for incompatibility.
1 1 Labeling deficiencies Failure to label or
improperly labeled
containers
12 Record submissions Inadequate training
(incomplete or late) records
1 3 Security and Safety Failure to operate in a
way that minimizes
fire or HW release
14 Record submissions Inspection logs
(incomplete or late)
0
1 Labeling deficiencies Failure to label or
improperly labeled
containers
2 Manifest and Failure to
transport problems, prepare/improper/illegi
LDR certification ble preparation of the
manifest.
3 Record submissions Inspection logs
(incomplete or late)
4 Unpermitted and TSD of HW without
unauthorized activity permit or interim status
$0
$0
$0
$0
$0
$0
$0 3/14/94 Final $14,000
$0
$0
$0
$0
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 Slate
7/28/94 $8,000 1994 State
$0 1994 State
$0 1994 Slate
$0 1994 Slate
$0 1994 Stale
C-l-15
; RCRA inspection took place before 10/92, therefore no penalises were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility Region State Dept
Guard " s'/sCJ'. 'VVv*>S '; ',„ f "t^
Vermont Air N 01 VT AF
Guard
Vermont Air N 01 VT AF
Guard
Vermont Air N 01 VT AF
Guard
Vermont Air N 01 VT AF
Guard
Vermont Air N 01 VT AF
Guard
Vermont Air N 01 VT AF
Guard
Vermont Air N 01 VT AF
Guard
Vermont Air N 01 VT AF
Guard
Vermont Air N 01 VT AF
Guard
Wright P«|ter$oti;s '.'^Ojj'l ^,OH' y^'AF'- <.
Docket # Count Violation
Category
^^04i:;|A;-;®
1-95-1049 1 General O&M
failures
1-95-1049 2 Storage and
accumulation issues
1-95-1049 3 Storage and
accumulation issues
1-95-1049 4 Labeling deficiencies
1-95-1049 5 General O&M
failures
1-95-1049 6 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
1-95-1049 7 Record submissions
(Incomplete or late)
1-95-1049 8 Inspections and
engineering
certification
1-95-1049 9 Reports
^ISIslisMS^
Violation
Description
\ > '• ! '
Incomplete or failure
to make HW
determination
Storage beyond
permitted time limits
Failure to properly
locate/control SAAs
Failure to label or
improperly labeled
containers
Use of defective
containers
Contingency plans
Failure to maintain or
provide records
Failure to perform, or
Inadequate inspections
required In permits or
by Federal/state/local
regulations.
Failure to submit
required annual
hazardous waste
assessment reports
Vli^y :
Violation Issue
Penalty Date
$0 6/27/95
$25,000 6/27/95
$6,500 6/27/95
$6,500 6/27/95
$6,500 6/27/95
$6,500 6/27/95
$6,500 6/27/95
$10,800 6/27/95
$6,500 6/27/95
$6,500 6/27/95
- , ;,;,», $0 9/30/94
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
Neg $81,300 $0 1995
1995
1995
1995
1995
1995
1995
1995
1995
1995
Final $102,400 1/19/95 $60,200 1994
Issued
By
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
C-l-16
1 RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air Force (cont.)
Facility Region
Wright Patterson 05
AFB
Wright Patterson 05
AFB
Wright Patterson 05
AFB
Wright Patterson 05
AFB
Wright Patterson 05
AFB
Wright Patterson 05
AFB
Wright Patterson 05
AFB
Wright Patterson 05
AFB
State Dept Docket # Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
Penalty
OH AF 5-W-026-94 1 Manifest and Failure to obtain date $5,150 9/30/94 1994 EPA
transport problems, and/or nu mber of
LDR certification manifest
OH AF 5-W-026-94 2 Reports Failure to submit $300 9/30/94 1994 EPA
required
(miscellaneous) reports
OH AF 5-W-026-94 3 Storage and Failure to indicate $4,000 9/30/94 1994 EPA
accumulation issues accumulation or
storage start dates on
containers
OH AF 5-W-026-94 4 Labeling deficiencies Failure to label or $4,000 9/30/94 1994 EPA
improperly labeled
containers
OH AF 5-W-026-94 5 General O&M Failure to close $6,500 9/30/94 1994 EPA
failures hazardous waste
(HW) containers
OH AF 5-W-026-94 6 Security and Safety Failure to provide $4,000 9/30/94 1994 EPA
personal protection
equipment
OH AF 5-W-026-94 7 Manifest and LDR notification $12,975 9/30/94 1994 EPA
transport problems, failure
LDR certification
OH AF 5-W-026-94 8 Storage and Storage beyond $57,475 9/30/94 1994 EPA
accumulation issues permitted time limits
C-l-17
* RCRA inspection took place before 10/92, therefore no penalities were proposed.
-------
SUMMARY OF RCRA ADMINISTRATIVE ORDERS
AIR NATIONAL GUARD
AIR NATIONAL GUARD VIOLATION SUMMARY (2nd level)
VIOLATION CATEGORY
47
42
44
71
43
45
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
4
3
2
1
1
1
12
DESCRIPTION OF VIOLATION
Manifest and transport problems, LDR certification
Record submissions (incomplete or late)
Storage and accumulation issues
Reports
Labeling deficiencies
General O&M failures
AVG PEN
NA
NA
NA
NA
NA
NA
C-2
-------
Summary of RCRA Administrative Orders - Air National Guard
Facility
Duluth ANGB
Dululh ANGB
Duluth ANGB
Dululh ANGB
Dululh ANGB
Duluth ANGB
RI Air National
Guard
RI Air National
Guard
RI Air National
Guard
RI Air National
Guard
RI Air National
Guard
Region State Dept Docket # Count Violation
Category
05 MN ' AND None 0
05 MN ANG None 1 Reports
05 MN ANG None 2 Storage and
accumulation issues
05 MN ANG None 3 Storage and
accumulation issues
05 MN ANG None 4 Labeling deficiencies
05 MN ANG None 5 Record submissions
(incomplete or late)
01 RI ANO '1-93-1078 0
01 RI ANG I-93-I078 1 General O&M
failures
01 RI ANG 1-93-1078 2 Manifest and
transport problems,
LDR certification
01 RI ANG 1-93-1078 3 Manifest and
transport problems,
LDR certification
01 RI ANG 1-93-1078 4 Manifest and
transport problems,
LDR certification
Violation
Description
Failure to file
exception reports
Storage of HW
without interim status
or permit
Failure to indicate
accumulation or
storage start dates on
containers
Failure to label or
Improperly labeled
containers
Failure to maintain or
provide records
Incomplete or failure
to make HW
determination
Notification failure of
treatment standards
LDR notification
failure
LDR notification
failure
Violation Issue Status Total
Penalty Date Proposed
Penalty
$0 10/12/92 Neg $1,945
$0
$0
$0
$0
$0
$0 8/20/93 Final $0
$0
$0
$0
$0
SEPS Settle Amount Year Issued
Date Paid Issued By
$0 1992 State
$0 1992 State
$0 1992 State
$0 1992 Stale
$0 1992 State
$0 1992 Stale
9/20/93 $0 1993 EPA
$0 1993 EPA
$0 1993 EPA
$0 1993 EPA
$0 1993 EPA
C-2-1
: RCRA inspection took place before 10/92, therfore no penalities were proposed.
-------
Summary of RCRA Administrative Orders - Air National Guard (com.)
Facility Region State Dept Docket # Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
- Penalty
RI Air National 01 RI ANO 1-93-1078 5 Manifest and LDR notification
transport problems, failure
LDR certification
$0
$0 1993 EPA
RI Air National 01 RI ANO 1-93-1078 6 Record submissions Land disposal
(incomplete or late) restriction (LDR)
certifications
$0
$0 1993 EPA
RI Air National 01 RI ANO 1-93-1078 7 Record submissions Failure to maintain or
(incomplete or late) provide records
$0
$0 1993 EPA
C-2-2
* RCRA inspection took place before 10/92, therfbre no penalities were proposed.
-------
SUMMARY OF RCRA ADMINISTRATIVE ORDERS
ARMY
ARMY VIOLATION SUMMARY (2nd level)
VIOLATION CATEGORY
44
45
43
42
73
47
72
41
71
22
46
49
51
48
63
33
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
41
35
24
18
17
13
12
11
10
4
4
3
3
2
1
1
199
DESCRIPTION OF VIOLATION
Storage and accumulation issues
General O&M failures
Labeling deficiencies
Record submissions (incomplete or late)
Forms, documents, plans, manuals, procedures - inadequate/incomplete
Manifest and transport problems, LDR certification
Security and Safety
Unpermitted and unauthorized activity
Reports
Groundwater monitoring
Faulty or missing equipment
Inspections and engineering certification
Unauthorized discharge/disposal
Nonlisted waste activities
Hazardous waste treatment, storage or disposal
Training: inadequate/not done
AVG PEN
$113,362
$25,936
$18,926
$10,417
$88,332
$10,975
$14,029
$191,568
$4,486
$35,978
$49,500
$50,500
$17,000
$3,500
$17,500
$51,250
C-3
-------
Summary of RCRA Administrative Orders - Army
Facility Region
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
State Dept Docket #
MD Army 3-R-94Q84
MD Army 3-R-94084
MD Army 3-R-94084
MD Army 3-R-94084
MD Army 3-R-94084
MD , Army OO-93-Q7Q
MD Army C-0-93-070
MD Army C-0-93-070
MD Army C-0-93-070
MD Army C-0-93-070
MD Army C-0-93-070
Count Violation
Category
0
1 Storage and
accumulation issues
2 Manifest and
transport problems,
LDR certification
3 Manifest and
transport problems,
LDR certification
4 Manifest and
transport problems,
LDR certification
0
1 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
2 Record submissions
(incomplete or late)
3 Record submissions
(incomplete or late)
4 Reports
5 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
Violation Violation Issue Status Total SEPS Settle Amount Year
Description Penalty Date Proposed Date Paid Issued
Penalty
$0 1/5/94 Final $115,546
Storage beyond $115,546 1/5/94
permitted time limits
LDR notification $0 1/5/94
failure
LDR certification $0 1/5/94
requirements.
Failure to obtain date $0 1/5/94
and/or number of
manifest
$0 2/25/93 Neg $5,000
Waste analysis plans $0
Failure to maintain or $0
provide records
Failure to maintain or $0
provide records
Failure to file manifest $0
reports
Contingency plans $0
7/17/95 $92,500 1994
1994
1994
1994
1994
$0 1993
$0 1993
$0 1993
$0 1993
$0 1993
$0 1993
Issued
By
EPA
EPA
EPA
EPA
EPA
State
State
State
State
State
State
C-3-1
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
State Dept Docket # Count Violation Violation Violation Issue
Category Description Penalty Date
MD Army C-0-93-070 6 Record submissions Inspection logs $0
(incomplete or late)
MD Army C-0-93-070 7 Faulty or missing Violations resulting $0
equipment from inoperative,
poorly designated, or
nonexistent equipment
needed to meet permit
conditions and
regulatory
requirements or to
prevent releases of
pollutants into the
environment.
MD Army C-0-93-070 8 Faulty or missing Violations resulting $0
equipment from inoperative,
poorly designated, or
nonexistent equipment
needed to meet permit
conditions and
regulatory
requirements or to
prevent releases of
pollutants into the
environment.
MD Army C-0-93-070 9 Record submissions Inspection logs $0
(incomplete or late)
MD Army C-0-93-070 10 Record submissions Failure to maintain or $0
(incomplete or late) provide records
MD Army C-0-93-070 11 Record submissions Failure to maintain or $0
(incomplete or late) provide records
MD Army C-0-93-070 12 Forms, documents, Contingency plans $0
plans, manuals,
procedures -
inadequate or
incomplete
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
C-3-2
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
State Dept Docket # Count Violation
Category
MD Army C-0-93-070 13 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
MD Army C-0-93-070 14 Reports
MD Army C-0-93-070 15 Reports
MD Army C-0-93-070 16 Faulty or missing
equipment
MD Army C-0-94-039 0
MD Army C-0-94-039 1 Reports
MD Army C-0-94-039 2 Reports
MD Army C-0-94-039 3 Manifest and
transport problems,
LDR certification
Violation Violation Issue
Description Penalty Date
Contingency plans $0
Failure to file $0
exception reports
Failure to submit $0
required annual
hazardous waste
assessment reports
Violations resulting $0
from inoperative,
poorly designated, or
nonexistent equipment
needed to meet permit
conditions and
regulatory
requirements or to
prevent releases of
pollutants into the
environment.
$0 1/13/94
Failure to file $0
exception reports
Failure to file manifest $0
reports
Failure to $0
prepare/improper/illegi
ble preparation of the
manifest.
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
Ncg $25,000 $0 1993 State
$0 1994 State
$0 1994 Stale
$0 1994 State
C-3-3
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
State Dcpt Docket # Count Violation Violation
Category Description
MD Army C-0-94-039 4 Restricted/Nonlisted Failure to
waste activities submit/retain and
notification for
restricted wastes
shipped off-site
MD Army C-0-94-039 5 Reports Failure to file
exception reports
MD Army C-0-94-039 6 Storage and Storage beyond
accumulation Issues permitted time limits
MD Army C-0-94-039 7 Unauthorized Discharges or disposal
discharge/disposal of regulated
substances has
occurred without
proper permits and in
violation of Federal,
state, or local
regulations.
MD Army C-0-94-039 8 Storage and Storage beyond
accumulation issues permitted volume
MD Army C-0-94-039 9 Storage and Storage of HW in
accumulation issues areas not identified by
permit
MD Army C-0-94-039 10 Storage and Storage beyond
accumulation issues permitted volume
MD Army C-0-94-039 11 General O&M Incomplete or failure
failures to make HW
determination
MD Army C-0-94-039 12 Forms, documents, Waste analysis plans
plans, manuals,
procedures -
inadequate or
incomplete
Violation Issue
Penalty Date
$0
$0
$0
$0
$0
$0
$0
$0
$0
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
$0 1994 State
$0 1994 State
$0 1994 Slate
$0 1994 State
$0 1994 Stale
$0 1994 Slate
$0 1994 State
$0 1994 State
$0 1994 State
C-3-4
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Aberdeen Proving 03
Ground
Camp Stanley 06
Camp Stanley 06
Camp Stanley 06
Def Reutil & 04
Market
State Dept
MD Army
MD Army
MD Army
MD Army
MD Army
MD Army
MD Army
TX Army
TX Army
TX Army
TN Army
Docket #
C-O-94-039
C-0-94-039
C-O-94-039
C-0-94-039
C-O-94-039
C-0-94-039
C-0-94-039
RCRA-6-3JO-
H
RCRA-6-310-
H
RCRA-6-310-
H
94-07-R
Count Violation
Category
13 Storage and
accumulation issues
14 General O&M
failures
IS Labeling deficiencies
16 General O&M
failures
17 General O&M
failures
18 Reports
19 Record submissions
(incomplete or late)
0
1 Unpermitted and
unauthorized activity
2 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
0
Violation
Description
Storage of HW in
areas not identified by
permit
Failure to close
hazardous waste
(HW) containers
Failure to label or
improperly labeled
containers
Incomplete or failure
to make HW
determination
Incomplete or failure
to make HW
determination
Failure to submit
required annual
hazardous waste
assessment reports
Failure to maintain or
provide records
TSD of HW without
permit or interim status
Closure and post
closure plans
Violation Issue
Penalty Date <
$0
$0
$0 .
$0
$0
$0
$0
$0 6/30/93
$346,500 6/30/93
$346,500 6/30/93
$0 9/13/94
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 Slate
$0 1994 State
$0 1994 State
$0 1994 Slate
Neg $693,000 $0 1993 EPA
1993 EPA
1993 EPA
Neg $66,500 $0 1994 EPA
C-3-5
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
DcfReutll& 04
Market
DcfReulil& 04
Market
DcfReutil& 04
Market
DefReutil& 04
Market
DefRculil& 04
Market
Ft. Bliss 06
Ft. Bliss 06
Ft. Bliss ;-*;<:' < -: 06 '
Ft. Bliss 06
Ft. Bliss 06
Ft. Bliss 06
State Dept Docket # Count Violation
Category
TN Army 94-07-R 1
TN Army 94-07-R 2
TN Army 94-07-R 3
TN Army 94-07-R 4
TN Army 94-07-R 5
TX Army NMHWA93- 0
14 '
TX Army NMHWA93- 1
14
TX Army None 1
TX Army None 2
TX Army None 3
General O&M
failures
Labeling deficiencies
Security and Safety
General O&M
failures
Record submissions
(incomplete or late)
General O&M
failures
Groundwater
monitoring
Unauthorized
discharge/disposal
General O&M
failures
Violation Violation Issue Status Total SEPS Settle Amount Year
Description Penalty Date Proposed Date Paid Issued
Incomplete or failure $17,500 9/13/94
to make HW
determination
Failure to label or $9,500 9/1 3/94
Improperly labeled
containers
Failure to operate in a $25,000 9/13/94
way that minimizes
fire or HW release
Failure to close $9,500 9/13/94
hazardous waste
(HW) containers
Inspection logs $5,000 9/13/94
$0 8/23/93 Final $1,260
Incomplete or failure $1,260
to make HW
determination
'''/'•'"• . •- $0 12/13/93 Neg $127,239
Inadequate $8,400
groundwater
monitoring and/or
sampling
Discharges to "waters $8,800
of the U.S." without a
permit
Incomplete or failure $19,200
to make HW
determination
1994
1994
1994
1994
1994
3/10/94 $800 1993
$0 1993
$0 1993
$0 1993
$0 1993
$0 1993
Issued
By
EPA
EPA
EPA
EPA
EPA
State
State
State
State
State
State
C-3-6
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility
Ft. Bliss
Ft. Bliss
Ft. Bliss
Ft. Bliss
Ft. Dix
Ft. Dix
Ft. Dix
Ft. Dix
Ft. Dix
Ft. Dix
Region State Dept Docket #
06 TX Army None
06 TX Army None
06 TX Army None
06 TX Army None
02 NJ Army None -
02 NJ Army None
02 NJ Army None
02 NJ Army None
02 NJ Army None
02 NJ Army None
Count Violation Violation
Category Description
4 Storage and Failure to indicate
accumulation issues accumulation or
storage start dates on
containers
5 Reports Failure to submit
required annual
hazardous waste
assessment reports
6 Forms, documents, Closure and post
plans, manuals, closure plans
procedures -
inadequate or
incomplete
7 Storage and Storage beyond
accumulation issues permitted volume
0
1 Manifest and Failure to
transport problems, prcpare/iinproper/illcgi
LDR certification ble preparation of the
manifest.
2 Manifest and Failure to
transport problems, prepare/iinproper/illegi
LDR certification ble preparation of the
manifest.
3 Manifest and Failure to obtain date
transport problems, and/or number of
LDR certification manifest
4 Reports Failure to file
exception reports
5 Storage and Storage beyond
accumulation issues permitted volume
Violation Issue
Penalty Date
$280
$959
$70,400
$10,000
$0 8/12/93
$600
$1,000
$600
$3,000
$2,000
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1993 State
$0 1993 State
$0 1993 Slate
$0 1993 State
Neg $18,200 $0 1993 State
$0 1993 State
$0 1993 State
$0 1993 Stale
$0 1993 Slate
$0 1993 Slate
C-3-7
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Ft. Dix 02
Ft. Dix 02
Rdiltem .:, 04
Ft. Gillcm 04
Ft. Gillem 04
Ft. Gillem 04
Ft. Gillem 04
Ft. Gillem 04
Ft. Gillem 04
Ft. Gillem 04
State Dept Docket # Count Violation
Category
NJ Army None 6 Storage and
accumulation issues
NJ Army None 7 General O&M
failures
OA Army, EPD-HW-t070 0
GA Army EPD-HW-1070 1 Storage and
accumulation issues
GA Army EPD-HW-1070 2 Record submissions
(incomplete or late)
GA Army EPD-HW-1070 3 General O&M
failures
GA Army EPD-HW-1070 4 Record submissions
(Incomplete or late)
GA Army EPD-HW-1070 5 Record submissions
(incomplete or late)
GA Army EPD-HW-1070 6 General O&M
failures
GA Army EPD-HW-1070 7 Labeling deficiencies
Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Description Penalty Date Proposed Date Paid Issued By
Failure to Indicate $ 1 0,000
accumulation or
storage stan dates on
containers
Failure to close $1,000
hazardous waste
(HW) containers
$0 8/27/93 Final $50,000
Storage of HW $0
without interim status
or permit
Violations concerning $0
operating records,
flies, etc., not
maintained in
accordance with
regulations, to include
incomplete or late
submittals.
Use of defective $0
containers
Failure to maintain or $0
provide records
Inadequate training $0
records
Incomplete or failure $0
to make HW
determination
Failure to label or $0
improperly labeled
containers
$0 1993 State
$0 1993 Stale
3/4/94 $50,000 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 Stale
C-3-8
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility
Ft.
Ft,
Ft.
Ft.
Ft.
Ft.
Ft.
Ft.
Ft.
Ft.
Gillcm
Hood
Hood
Hood
Hood
Hood
Hood
Hood
Hood
Hood
Region State Dept
04 OA Army
06 TX Army,
06 TX Army
06 TX Army
06 TX Army
06 TX Army
06 TX Army
06 TX Army
06 TX Army
06 TX Army
Docket #
EPD-HW-1070
None
None
None
None
None
None
None
RCRA-6-323-
H
RCRA-6-323-
H
Count
8
0
1
2
3
4
5
6
0
1
Violation
Category
Storage and
accumulation issues
Unauthorized
discharge/disposal
Storage and
accumulation issues
Manifest and
transport problems,
LDR certification
Labeling deficiencies
Unpermitted and
unauthorized activity
Manifest and
transport problems,
LDR certification
Manifest and
transport problems,
LDR certification
Violation
Description
Failure to indicate
accumulation or
storage start dates on
containers
Discharges to "waters
of the U.S." without a
permit
Storage of HW
without interim status
or permit
Failure to
prepare/improper/illegi
ble preparation of the
manifest.
Failure to label or
improperly labeled
containers
Unpermitted activities,
or equipment, within a
permitted program
Failure to
prepare/improper/illegi
ble preparation of the
manifest.
!
Failure to
prepare/improper/illegi
ble preparation of the
manifest.
Violation Issue
Penalty Date
$0
$0 10/1/93
$25,200
$67,200
$43,600
$3,440
$0
$0
$0 10/1/93
$22,500 10/1/93
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1993 State
Neg $139,440 $0 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 Slate
Neg $1,326,750 $0 1993 EPA
1993 EPA
C-3-9
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Fl. Hood 06
Ft. Hood 06
Ft. Hood 06
Ft. Hood 06
Ft, Hunter Liggett 09 ,
Ft. Hunter Liggett 09
Ft. Hunter Liggett 09
Ft. Hunter Liggett 09
Ft. Hunter Liggett 09
State Dept Docket #
TX Army RCRA-6-323-
H
TX Army RCRA-6-323-
H
TX Army RCRA-6-323-
H
TX Army RCRA-6-323-
H
, CA Army FO 92/93-2-
- / 003;, ,., ',
CA Army FO 92/93-2-
003
CA Army FO 92/93-2-
003
CA Army FO 92/93-2-
003
CA Army FO 92/93-2-
003
Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
Penalty
2 Storageand Failure to indicate $354,750 10/1/93 1993 EPA
accumulation issues accumulation or
storage start dates on
containers
3 Unpermitted and TSD of HW without $448,500 10/1/93 1993 EPA
unauthorized activity permit or interim status
4 Unpermitted and TSD of HW without $448,500 10/1/93 1993 EPA
unauthorized activity permit or interim status
5 Forms, documents, Closure and post $52,500 10/1/93 1993 EPA
plans, manuals, closure plans
procedures -
inadequate or
incomplete
/ ,0 , ' $0 4/16/93 Keg $1,050 $0 1993 State
1 Labeling deficiencies Failure to label or $400 $0 1993 State
Improperly labeled
containers
2 Labeling deficiencies Failure to label or $50 $0 1993 State
improperly labeled
containers
3 Forms, documents, Contingency plans $200 $0 1993 State
plans, manuals,
procedures -
inadequate or
incomplete
4 General O&M Failure to close $200 $0 1993 State
failures hazardous waste
(HW) containers
C-3-10
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Ft. Hunter Liggett 09
FUrwitiNat 09
Training '•' " ' ;
Ft. Irwin Nat 09
Training
Ft. Irwin Nat 09
Training
Ft. Irwin Nat 09
Training
Ft. Irwin Nat 09
Training
Ft. Irwin Nat 09
Training
Ft. McCoy 05
Ft. McCoy 05
Ft, Ord 09
Ft. Ord 09
Ft. Ord 09
State
CA
CA
CA
CA
CA
CA
CA
WI
WI
CA
CA
CA
Dept Docket #
Army FO 92/93-2-
003
Army DO 92/93-
, M 4100 -
Army DO 92/93-
4100
Army DO 92/93-
4100
Army DO 92/93-
4100
Army DO 92/93-
4100
Army DO 92/93-
4100
Army V-W-2U93
Army V-W-21-93
Army DO 93/94-2-
007
Army DO 93/94-2-
007
Army DO 93/94-2-
007
Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
Penalty
5 Forms, documents, Contingency plans $200
plans, manuals,
procedures -
inadequate or
incomplete
0 $0 4/26/93 Neg $42,338
1 Labeling deficiencies Failure to label or $0
improperly labeled
containers
2 Record submissions Inspection logs $0
(incomplete or late)
3 Security and Safety Failure to operate in a $0
way that minimizes
fire or HW release
4 General O&M Failure to close $0
failures hazardous waste
(HW) containers
5 Security and Safety Failure to provide $0
personal protection
equipment
0 $0 7/17/93 Final $16,875
1 Unpermitted and TSD of HW without $16,875 7/17/93
unauthorized activity permit or interim status
0 ' $0 11/1/93 Final $8,650
1 Storage and Storage beyond $0
accumulation issues permitted time limits
2 Labeling deficiencies Failure to label or $0
improperly labeled
containers
$0 1993 State
$0 1993 State
$0 1993 Stale
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 Slate
2/16/95 $6,084 1993 EPA
1993 EPA
11/4/94 $6,137 1993 State
$0 1993 State
$0 1993 State
C-3-11
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region State
Ft. Ord 09 CA
Ft. Ord 09 CA
Ft. Ord 09 CA
Ft. Ord 09 CA
Ft. Ord 09 CA
Ft. Ord 09 CA
Ft. Ord 09 CA
Ft. Richardson -' v,; :10 ,, , AK:
Ft. Richardson 10 AK
Ft. Richardson 10 AK
Ft. Richardson 10 AK
Dept Docket #
Army DO 93/94-2-
007
Army DO 93/94-2-
007
Army DO 93/94-2-
007
Army DO 93/94-2-
007
Army DO 93/94-2-
007
Army DO 93/94-2-
007
Army DO 93/94-2-
007
>~ Array J1093.0&18;
•, -/•• 360$ < -'
Army 1093-06-18-
3008
Army 1093-06-18-
3008
Army 1093-06-18-
3008
Count Violation Violation Violation Issue Status Total
Category Description Penalty Date Proposed
Penalty
3 Storage and Failure to properly $0
accumulation Issues date containers in
SAAs
4 Storage and Failure to indicate $0
accumulation issues accumulation or
storage start dates on
containers
5 Storage and Storage beyond $0
accumulation issues permitted time limits
6 Unpermittcd and Unpermifled activities, $0
unauthorized activity or equipment, within a
permitted program
7 Record submissions Failure to maintain or $0
(incomplete or late) provide records
8 Security and Safety Failure to provide $0
personal protection
equipment
9 Record submissions Failure to maintain or $0
(incomplete or late) provide records
<„; 0 ' ' ' ; - $0 4/29/94 Neg $1,352,582
1 Storage and Failure to indicate $615,450 4/29/94
accumulation issues accumulation or
storage start dates on
containers
2 General O&M Incomplete or failure $49,500 4/29/94
failures to make HW
determination
3 Record submissions Failure to maintain or $19,250 4/29/94
(incomplete or late) provide records
SEPS Settle Amount Year Issued
Date Paid Issued By
$0 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 State
$0 1993 Stale
$0 1993 State
$0 1993 State
$0 1994 EPA
1994 EPA
1994 EPA
1994 EPA
•
C-3-12
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility
Ft. Richardson
Ft. Richardson
Ft. Richardson
Ft. Richardson
Ft. Richardson
Ft. Richardson
Ft. Richardson
Ft. Richardson
Ft. Richardson
Ft.Wainwright
Region State Dept Docket #
10 AK Army 1093-06-18-
3008
10 AK Army 1093-06-18-
3008
10 AK Army 1093-06-18-
3008
10 AK Army 1093-06-18-
3008
10 AK Army 1093-06-18-
3008
10 AK Army 1093-06-18-
3008
10 AK Army 1093-06-18-
3008
10 AK Army 1093-06-18-
3008
10 AK Army 1093-06-18-
3008
10 AK Army 1093-09-09-
3008
Count Violation
Category
4 Security and Safety
5 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
6 Record submissions
(incomplete or late)
7 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
8 Storage and
accumulation issues
9 Hazardous waste
treatment, storage or
disposal
10 General O&M
failures
1 1 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
12 Labeling deficiencies
0
Violation
Description
Inadequate aisle space
for egress
Contingency plans
Failure to maintain or
provide records
Closure and post
closure plans
Storage beyond
permitted time limits
Design deficiencies for
HWTSD facility -
Structural flaws in
storage areas
Incomplete or failure
to make HW
determination
Waste analysis plans
Failure to label or
improperly labeled
containers
Violation
Penalty
$35,000
$172,075
$16,000
$189,282
$10,450
$17,500
$49,500
$172,075
$6,500
$0
Issue
Date
4/29/94
4/29/94
4/29/94
4/29/94
4/29/94
4/29/94
4/29/94
4/29/94
4/29/94
4/29/94
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
1994
1994
1994
1994
1994
1994
1994
1994
1994
Neg $659,450 $0 1994
Issued
By
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
C-3-13
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility
Ft. Wainwright
Fl. Wainwright
Ft. Wainwright
Ft. Wainwright
Ft. Wainwright
Ft. Wainwright
Hunter Army
Airfield
Hunter Army
Airfield
Hunter Army
Airfield
Hunter Army
Airfield
Region State Dept Docket # Count
10 AK Army 1093-09-09- 1
3008
10 AK Army 1093-09-09- 2
3008
10 AK Army 1093-09-09- 3
3008
10 AK Army 1093-09-09- 4
3008
10 AK Army 1093-09-09- 5
3008
10 AK Army 1093-09-09- 6
3008
'04 OA < Army Et>J>-HW-i068 : 6
/',''"' - •'•''• " '-;' '•' 'J X, /• ••'
04 GA Army EPD-HW-1068 1
04 GA Army EPD-HW-1068 2
04 GA Army EPD-HW-1068 3
Violation Violation Violation Issue Status Total
Category Description Penalty Date Proposed
Penalty
General O&M Incomplete or failure $19,250 4/29/94
failures to make HW
determination
Storage and Failure to indicate $615,450 4/29/94
accumulation issues accumulation or
storage start dates on
containers
Reports Failure to submit $9,500 4/29/94
notice of non-
compliance
Labeling deficiencies Failure to label or $6,500 4/29/94
improperly labeled
containers
Forms, documents, Waste analysis plans $2,250 4/29/94
plans, manuals,
procedures -
inadequate or
incomplete
Manifest and LDR certification $6,500 4/29/94
transport problems, requirements.
LDR certification
/,, ',',,,; «'„-''".'- •;',--,, „••"•'•"• ,;$Q 9/20/93 Final $25,000
• , ' >'',",. ' ' ' '.,,'•',','•
Labeling deficiencies Failure to label or $0
improperly labeled
containers
General O&M Incomplete or failure $0
failures to make HW
determination
Storage and Failure to indicate $0
accumulation issues accumulation or
storage start dates on
containers
SEPS Settle Amount Year
Date Paid Issued
1994
1994
1994
1994
1994
1994
2/28/94 ,$25,000 1993
$0 1993
$0 1993
$0 1993
Issued
By
EPA
EPA
EPA
EPA
EPA
EPA
State
Slate
State
State
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Hunter Army 04
Airfield
Iowa Ammo Plant 07
Iowa Ammo Plant 07
Iowa Ammo Plant 07
Iowa Ammo Plant 07
Iowa Ammo Plant 07
Iowa Ammo Plant 07
Iowa Ammo Plant 07
State Dept Docket # Count Violation
Category
GA Army EPD-HW-1068 4 Inspections and
engineering
certification
IA Army 7-93-H.W3 0
IA Army 7-93-H-003 1 Groundwater
monitoring
IA Army 7-93-H-003 2 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
IA Army 7-93-H-003 3 Groundwater
monitoring
IA Army 7-93-H-003 4 Storage and
accumulation issues
IA Army 7-93-H-003 5 Unpermitted and
unauthorized activity
IA Army 7-93-H-003 6 Storage and
accumulation issues
Violation Violation
Description Penalty
Failure to perform, or $0
inadequate inspections
required in permits or
by Federal/state/local
regulations.
$0
Failure to determine $9 1 ,786
rate and extent of
migration of HW in
ground water.
Closure and post $ 1 ,002
closure plans
Failure to $33,527
develop/implement a
groundwater
monitoring program
capable of determining
(he facility's impact on
quality of groundwater.
Failure to indicate $0
accumulation or
storage start dates on
containers
Unpermitted activities, $0
or equipment, within a
permitted program
Storage of HW in $0
areas not identified by
permit
Issue
Date
5/19/93
5/19/93
5/19/93
5/19/93
5/19/93
5/19/93
5/19/93
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
$0 1993
Final $201,640 $300,000 12/31/94 $138,922 1993
1993
1993
1993
1993
1993
1993
Issued
By
Slate
EPA
EPA
EPA
EPA
EPA
EPA
EPA
C-3-15
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Iowa Ammo Plant 07
Iowa Ammo Plant 07
Iowa Ammo Plant 07
Iowa Ammo Plant 07
Iowa Ammo Plant 07
Iowa Ammo Plant 07
Johnston Atoll 09
Johnston Atoll 09
Johnston Atoll 09
State Dept Docket # Count Violation
Category
IA Army 7-93-H-003 7 General O&M
failures
IA Army 7-93-H-003 8 Faulty or missing
equipment
IA Army 7-93-H-003 9 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
LA Army 7-93-H-003 10 Record submissions
(incomplete or late)
Violation
Description
Incomplete or failure
to make HW
determination
Violations resulting
from Inoperative,
poorly designated, or
nonexistent equipment
needed to meet permit
conditions and
regulatory
requirements or to
prevent releases of
pollutants into the
environment.
Required certifications
Inspection logs
IA Army 7-93-H-003 11 Unpermitted and Unpermitted activities,
unauthorized activity or equipment, within a
permitted program
LA Army 7-93-H-003 12 Monitoring errors
and failures
Oconus Army RCRA-09-95- 0
0001- _,;, - - , " , >> '
Failure to comply with
monitoring protocol.
Oconus Army RCRA-09-95- 1 Unpermitted and Unpermitted activities,
000 1 unauthorized activity or equipment, within a
permitted program
Oconus Army RCRA-09-95- 2 General O&M
0001 failures
Lack of proper aisle
space in storage areas
Violation
Penalty
$13,073
$49.500
$2,251
$0
$301
$10,200
$0
$50,000
$4,000
Issue
Date
5/19/93
5/19/93
5/19/93
5/19/93
5/19/93
5/19/93
3/13/95
3/13/95
3/13/95
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
1993
1993
1993
1993
1993
1993
Final $122,300 10/3/95 $91,700 1995
1995
1995
Issued
By
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
C-3-16
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Johnston Atoll 09
Natick Reasearch 01
Facility
Natick Reasearch 01
Facility
Natick Reasearch 01
Facility
Natick Reasearch 01
Facility
Natick Reasearch 01
Facility
Nalick Reasearch 01
Facility
Natick Reasearch 01
Facility
Newport AAP 05
Newport AAP 05
Newport AAP 05
State Dept Docket # Count Violation Violation Violation Issue Status Total SEPS
Category Description Penalty Date Proposed
Penalty
Oconus Army RCRA-09-95- 3 Storage and Storage of HW $68,300 3/13/95
0001 accumulation issues without interim status
or permit
MA Army I-94-1068 0 $0 8/30/94 Final $117,000
MA Army 1-94-1068 1 General O&M Incomplete or failure $79,500
failures to make HW
determination
MA Army 1-94-1068 2 Labeling deficiencies Failure to label or $2,250
improperly labeled
containers
MA Army 1-94-1068 3 Storage and Failure to indicate $22,500
accumulation issues accumulation or
storage start dates on
containers
MA Army 1-94-1068 4 General O&M Failure to close $4,000
failures hazardous waste
(HW) containers .
MA Army 1-94-1068 5 Labeling deficiencies Failure to label or $2,250
improperly labeled
containers
MA Army 1-94-1068 6 Security and Safety Failure to post $6,500
hazardous waste
management areas
IN Army H-H529 0 $0 8/1/94 Neg $15,500
IN Army H-11529 1 General O&M Incomplete or failure $10,000
failures to make HW
determination
IN Army H-11529 2 Restricted/Nonlisted Failure to properly $3,500
waste activities identify and treat
restricted wastes as
required by regulations
Settle Amount Year Issued
Date Paid Issued By
1995 EPA
$49,000 1994 EPA
$0 1994 EPA
$0 1994 EPA
$0 1994 EPA
$0 1994 EPA
$0 1994 EPA
$0 1994 EPA
$0 1994 State
$0 1994 Stale
$0 1994 Stale
C-3-17
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Newport AAP 05
Plcaiinny Arsenal 02
Picatinny Arsenal 02
Picalinny Arsenal 02
Presidio of San ' 09
Presidio of San 09
Francisco
Presidio of San • 09
Francisco
Presidio of San 09
Francisco
Presidio of San 09
Francisco
Presidio of San 09
Francisco
State Dept Docket #
IN Army H-11529
NJ •'• Amy 2-RCRA-94.
0103 '; ,-'•"•'
NJ Army 2-RCRA-94-
0103
NJ Army 2-RCRA-94-
0103
CA Army 9-94^008
- /- ''•"" , '
CA Army 9-94-0008
CA Army 9-94-0008
CA Army 9-94-0008
CA Army 9-94-0008
CA Army 9-94-0008
Count
3
,;•', 0
1
2
o; ,
''
i
2
3
4
5
Violation
Category
Labeling deficiencies
Storage and
accumulation issues
Unpermitted and
unauthorized activity
- -' '',,"' ;
Storage and
accumulation issues
General O&M
failures
Security and Safety
General O&M
failures
Inspections and
engineering
certification
Violation Violation Issue
Description Penalty Date
Failure to label or $2,000
Improperly labeled
containers
, '"„. ',,','• $0 8/29/94
Storage of HW $29,850 8/29/94
without interim status
or permit
Unpermitted activities, $30,300 8/29/94
or equipment, within a
permitted program
$0 5/9/94
Failure to indicate $43,500 5/9/94
accumulation or
storage start dates on
containers
Incomplete or failure $202,500 5/9/94
to make HW
determination
Inadequate aisle space $25,000 5/9/94
for egress
Failure to close $10,000 5/9/94
hazardous waste
(HW) containers
Failure to perform, or $72,500 5/9/94
inadequate inspections
required in permits or
by Federal/state/local
regulations.
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
$0 1994
Final $60,150 9/29/95 $41,565 1994
1994
1994
Final $556,500 4/22/96 $32,350 1994
1994
1994
1994
1994
1994
Issued
By
State
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
C-3-18
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Presidio of San 09
Francisco
RiverbankArmy 09
Depot
Rivcrbank Army 09
Depot
Riverbank Army 09
Depot
Riverbank Army 09
Depot
Rivcrbank Army 09
Depot
Schofield 09
Schofield 09
Schofield 09
Schofield 09
State Dept Docket #
CA Army 9-94-0008
CA Army FO 93/94-
- 1751
CA Army FO 93/94-
1751
CA Army FO 93/94-
1751
CA Army FO 93/94-
1751
CA Army FO 93/94-
1751
HI Array 9-944)005
HI Army 9-94-0005
HI Army 9-94-0005
HI Army 9-94-0005
Count Violation Violation Violation Issue
Category Description Penalty Date
6 Labeling deficiencies Failure to label or $202,500 5/9/94
improperly labeled
containers
' 0 ' , ',. , _ $0 1/13/94
1 Storage and Failure to indicate $200
accumulation issues accumulation or
storage start dales on
containers
2 Labeling deficiencies Failure to label or $100
improperly labeled
containers
3 Security and Safety Failure to operate in a $500
way that minimi7.es
fire or HW release
4 General O&M Failure to close $200
failures hazardous waste
(HW) containers
0 $0 5/3/94
1 Storage and Failure to indicate $201,500 5/3/94
accumulation issues accumulation or
storage start dates on
containers
2 General O&M Incomplete or failure $95,400 5/3/94
failures to make HW
determination
3 Storage and Failure to indicate $49,500 5/3/94
accumulation issues accumulation or
storage start dates on
containers
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
1994
Neg $1,000 $0 1994
$0 1994
$0 1994
$0 1994
$0 1994
Final $543,900 $1,245,135 9/26/95 $77,347 1994
1994
1994
1994
Issued
By
EPA
State
State
State
State
Slate
EPA
EPA
EPA
EPA
C-3-19
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility
Schoficld
Schofleld
Schofield
Schoficlcl
Schofield
Schofield
Schofield
Schofield
Region State Dept Docket # Count Violation
Category
09 HI Army 9-94-0005 4 Labeling deficiencies
09 HI Army 9-94-0005 5 Inspections and
engineering
certification
09 HI Army 9-94-0005 6 General O&M
failures
09 HI Army 9-94-0005 7 Security and Safety
09 HI Army 9-94-0005 8 Security and Safety
09 HI Army 9-94-0005 9 General O&M
failures
09 HI Army 9-94-0005 10 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
09 HI Army 9-94-0005 11 Training:
Inadequate/not done
Violation Violation Issue
Description Penalty Date
Failure to label or $25,500 5/3/94
Improperly labeled
containers
Failure to perform, or $28,500 5/3/94
inadequate inspections
required in permits or
by Federal/state/local
regulations.
Lack of proper aisle $7,000 5/3/94
space in storage areas
Failure to operate in a $13,000 5/3/94
way that minimizes
fire or HW release
Failure to $4,000 5/3/94
provide/maintain
equipment to be
utilized in response to
emergencies
Use of defective $4,000 5/3/94
containers
Contingency plans $51,250 5/3/94
Inadequate training or $51,250 5/3/94
failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
1994
1994
1994
1994
1994
1994
1994
1994
Issued
By
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
C-3-20
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Schoficld 09
Schofield 09
Sierra Army 09
Depot
Sierra Army 09
Depot
Sierra Army 09
Depot
Sierra Army 09
Depot
Sierra Army 09
Depot
Sierra Army 09
Depot
Sierra Army 09
Depot
Sierra Army 09
Depot
State Dept Docket #
HI Army 9-94-0005
HI Army 9-94-0005
CA Army DO 93/94*
1001
CA Army DO 93/94-
1001
CA Army DO 93/94-
1001
CA Army DO 93/94-
1001
CA Army DO 93/94-
1001
CA Army DO 94/95-
1004
CA Army DO 94/95-
1004
CA Army DO 94/95-
1004
Count Violation Violation Violation Issue
Category Description Penalty Date
12 Manifest and LDR notification $6,500 5/3/94
transport problems, failure
LDR certification
13 Manifest and Failure to $6,500 5/3/94
transport problems, prepare/improper/illegi
LDR certification ble preparation of the
manifest,
0 $0 3/18/94
1 Storage and Failure to indicate $0
accumulation issues accumulation or
storage start dates on
containers
2 Labeling deficiencies Failure to label or $0
improperly labeled
containers
3 Storage and Failure to indicate $0
accumulation issues accumulation or
storage start dates on
containers
4 Storage and Failure to indicate $0
accumulation issues accumulation or
storage start dates on
containers
0 $0 11/2/94
1 Labeling deficiencies Failure to label or $0
improperly labeled
containers
2 Labeling deficiencies Hazardous waste $0
labels illegible
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
1994
1994
Final $10,000 $7,000 1994
$0 1994
$0 1994
$0 1994
$0 1994
Final $19,000 3/18/95 $7,000 1994
$0 1994
$0 1994
Issued
By
EPA
EPA
State
Slate
State
State
State
Slate
Stale
Slate
C-3-21
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region
Sierra Army 09
Depot
Sierra Army 09
Depot
Sierra Army 09
Depot
Sierra Army 09
Depot
Sierra Army 09
Depot
Sierra Army 09
Depot
Sierra Army 09
Depot
Sierra Army 09
Depot
Whites Sands ; 06
White Sands 06
White Sands 06
State Dept Docket # Count Violation Violation Violation Issue Status Total SEPS
Category Description Penalty Date Proposed
Penalty
CA Army DO 94/95-
1004
CA Army DO 94/95-
1004
CA Army DO 94/95-
1004
CA Army DO 94/95-
1004
CA Army DO 94/95-
1004
CA Army DO 94/95-
1004
CA Army DO 94/95-
1004
CA Army DO 94/95-
1004
NM Army NMHWA94r
- v '03 • ',
NM Army NMHWA94-
03
NM Army NMHWA94-
03
3 Storage and Failure to indicate
accumulation Issues accumulation or
storage start dates on
containers
4 Storage and Failure to properly
accumulation issues date containers in
SAAs
5 Labeling deficiencies Failure to label or
Improperly labeled
containers
6 Labeling deficiencies Failure to label or
improperly labeled
containers
7 Storage and Storage not in
accumulation issues accordance with
recognized standards
for Incompatibility.
8 Storage and Storage beyond
accumulation issues permitted time limits
9 General O&M Failure to close
failures hazardous waste
(HW) containers
10 Unpermitted and Failure to obtain
unauthorized activity permit/authorization
•' o >' •" '' :
1 General O&M Incomplete or failure
failures to make HW
determination
2 General O&M Incomplete or failure
failures to make HW
determination
$0
$0
$0
$0
$0
$0
$0
$0
$0 5/20/94 $145,606
$6,440
$1.417
Settle Amount Year Issued
Date Paid Issued By
$0 1994 Slate
$0 1994 State
$0 1994 Slate
$0 1994 State
$0 1994 Slate
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 Stale
$0 1994 State
C-3-22
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility
White Sands
White Sands
White Sands
White Sands
White Sands
White Sands
White Sands
White Sands
White Sands
White Sands
White Sands
Region State Dept Docket #
06 NM Army NMHWA94-
03
06 NM Army NMHWA94-
03
06 NM Army NMHWA94-
03
06 NM Army NMHWA94-
03
06 NM Army NMHWA94-
03
06 NM Army NMHWA94-
03
06 NM Army NMHWA94-
03
06 NM Army NMHWA94-
03
06 NM Army NMHWA94-
03
06 NM Army NMHWA95-
04
06 NM Army NMHWA95-
04
Count Violation Violation Violation Issue Status Total SEPS
Category Description Penalty Date Proposed
Penalty
3
4
5
6
7
8
9
10
11
0
1
General O&M Failure to close
failures hazardous waste
(HW) containers
General O&M Failure to close
failures hazardous waste
(HW) containers
General O&M Failure to close
failures hazardous waste
(HW) containers
Storage and Storage beyond
accumulation issues permitted volume
Storage and Storage beyond
accumulation issues permitted volume
Storage and Storage beyond
accumulation issues permitted volume
Security and Safety Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Record submissions Inspection logs
(incomplete or late)
Security and Safety Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Labeling deficiencies Failure to label or
improperly labeled
containers
$45,500
$21,500 -
$1,312
$49,140
$810
$810
$1,260
$1,417
$16,000
$0 4/14/95 Neg $5,500
$1,575
Settle Amount Year Issued
Date Paid Issued By
$0 1994 Slate
$0 1994 Slate
$0 1994 Slate
$0 1994 Stale
$0 1994 Slate
$0 1994 Slate
$0 1994 Slate
$0 1994 Slate
$0 1994 State
$0 1995 State
$0 1995 State
C-3-23
-------
Summary of RCRA Administrative Orders - Army (cont.)
Facility Region State Dept Docket # Count Violation
Category
Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Description Penalty Date Proposed Date Paid Issued By
Penalty
White Sands 06 NM Army NMHWA95-
04
2 Labeling deficiencies Failure to label or
improperly labeled
containers
$2,400
$0
1995 State
While Sands
06 NM Army NMHWA95-
04
3 General O&M
failures
Failure to close
hazardous waste
(HW) containers
$1,575
$0
1995 Slate
C-3-24
-------
SUMMARY OF RCRA ADMINISTRATIVE ORDERS
COAST GUARD
COAST GUARD VIOLATION SUMMARY (2nd level)
VIOLATION CATEGORY
44
45
22
73
71
43
33
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
5
3
1
1
1
1
1
13
DESCRIPTION OF VIOLATION
Storage and accumulation issues
General O&M failures
Groundwater monitoring
Forms, documents, plans
Reports
Labeling deficiencies
Training: inadequate or not done
AVG PEN
$131,548
$19,907
$401,464
$19,250
$9,500
$7,150
$35,537
C-4
-------
Summary of RCRA Administrative Orders - Coast Guard
Facility Region
Kodiak Support - iO
Center
Kodiak Support 10
Center
Kodiak Support 10
Center
Kodiak Support 10
Center
U.S. Coast Guard 01
Academy ,
U.S. Coast Guard 01
Academy
U.S. Coast Guard 01
Academy
U.S. Coast Guard 01
Academy
U.S. Coast Guard 01
Academy
State Dept Docket #
AK USCG 1094-07-05-
3008a
AK USCG 1094-07-05-
3008a
AK USCG 1094-07-05-
3008a
AK USCG 1094-07-05-
3008a
CT USCG 1-95-1053
!
CT USCG 1-95-1053
CT USCG 1-95-1053
CT USCG 1-95-1053
CT USCG 1-95-1053
Count
0
1
2
3
0
1
2
3
4
Violation
Category
Groundwater
monitoring
Storage and
accumulation issues
Storage and
accumulation issues
General O&M
failures
Storage and
accumulation issues
Labeling deficiencies
Storage and
accumulation issues
Violation Violation Issue
Description Penalty Date
$0 7/12/94
Failure to $401,464 7/12/94
develop/implement a
groundwater
monitoring program
capable of determining
the fncilily's impact on
quality of groundwater.
Failure to indicate $314,660 7/12/94
accumulation or
storage start dates on
containers
Failure to indicate $302,428 7/12/94
accumulation or
storage start dates on
containers
$0 9/21/95
Incomplete or failure $26,172
to make HW
determination
Storage beyond $13,750
permitted time limits
Failure to label or $7,150
improperly labeled
containers
Failure to indicate $4,400
accumulation or
storage start dates on
containers
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
Neg $1,018,522 $0 1994
1994
1994
1994
Final $171,809 $259,254 9/21/95 $0 1995
$0 1995
$0 1995
$0 1995
$0 1995
Issued
By
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
C-4-1
-------
Summary of RCRA Administrative Orders - Coast Guard (cont.)
Facility Region
U.S. Coast Guard 01
Academy
U.S. Coast Guard 01
Academy
U.S. Coast Guard 01
Academy
U.S. Coast Guard 01
Academy
U.S. Coast Guard 01
Academy
U.S. Coast Guard 01
Academy
State Dept Docket # Count Violation
Category
CT USCG 1-95-1053 5 Reports
CT USCG 1-95-1053 6 Training:
inadequate/not done
CT USCG 1-95-1053 7 General O&M
failures
CT USCG 1-95-1053 8 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
CT USCG 1-95-1053 9 General O&M
failures
CT USCG 1-95-1053 10 Storage and
accumulation issues
Violation
Description
Failure to submit HW
release report In timely
manner
Inadequate training or
failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
Lack of proper aisle
space In storage areas
Contingency plans
Failure to close
hazardous waste
(HW) containers
Failure to adequately
consider HW
Violation Issue
Penalty Date
$9,500
$35,537
$19,250
$19,250
$14,300
$22,500
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1995 EPA
$0 1995 EPA
$0 1995 EPA
$0 1995 EPA
$0 1995 EPA
$0 1995 EPA
incompatibilities
C-4-2
-------
SUMMARY OF RCRA ADMINISTRATIVE ORDERS
DLA
DLA VIOLATION SUMMARY (2nd level)
VIOLATION CATEGORY
45
44
47
43
42
33
NUMBER OF VIOLATIONS
2
2
1
1
1
1
DESCRIPTION OF VIOLATION
General O&M failures
Storage and accumulation issues
Manifest and transport problems, LDR certification
Labeling deficiencies
Record submissions (incomplete or late)
Training: inadequate/not done
AVG PEN
NA
NA
NA
NA
NA
NA
C-5
-------
Summary of RCRA Administrative Orders - DLA
Facility
Defense Depot
West
Defense Depot
West
Defense Depot
West
Defense Depot
West
Defense Depot
West
Defense Depot
West- - '.'
Defense Depot
West
Defense Depot
West
Defense Depot
West
Defense Depot
West
Region State Dept Docket #
09 , CA DLA DO 93/94,
1005 ,
09 CA DLA DO 93/94-
1005
09 CA DLA DO 93/94-
1005
09 CA DLA DO 93/94-
1005
09 CA DLA. DO 93/94-
1005
09 CA DLA DO 93/94-
'••',' , - ' ' 1501
09 CA DLA DO 93/94-
1501
09 CA DLA DO 93/94-
1501
09 CA DLA DO 93/94-
1501
09 CA DLA DO 93/94-
1501
Count
0
1
2
3
4
0
1
2
3
4
Violation
Category
Storage and
accumulation issues
General O&M
failures
Record submissions
(incomplete or late)
Manifest and
transport problems,
LDR certification
Storage and
accumulation issues
General O&M
failures
Labeling deficiencies
Training:
inadequate/not done
Violation
Description
Storage beyond
permitted time limits
Incomplete or failure
to make HW
determination
Failure to maintain or
provide records
Failure to
prcpare/impropcr/illegi
ble preparation of the
manifest.
,
Improper/careless HW
storage
Improper O&M of
containment facility
Failure to label or
improperly labeled
containers
Inadequate training or
failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
Violation Issue
Penalty Date
$0 8/5/94
$0
$0
$0
$0
$0 3/31/94
$0
$0
$0
$0
Status Total SEPS Settle Amount
Proposed Date Paid
Penalty
Neg $11,000 $0
$0
$0
$0
$0
Final $8,000 5/17/94 $8,000
$0
$0
$0
$0
Year
Issued
1994
1994
1994
1994
1994
1994
1994
1994
1994
1994
Issued
By
State
State
Slate
State
State
Slate
Slate
State
State
State
C-5-1
-------
SUMMARY OF RCRA ADMINISTRATIVE ORDERS
DOE
DOE VIOLATION SUMMARY (2nd level)
VIOLATION CATEGORY
45
43
44
72
42
41
47
73
71
49
33
NUMBER OF VIOLATIONS
36
25
22
15
9
9
5
3
3
3
3
DESCRIPTION OF VIOLATION
General O&M failures
Labeling deficiencies
Storage and accumulation issues
Security and Safety
Record submissions (incomplete or late)
Unpermitted and unauthorized activity
Manifest and transport problems, LDR certification
Forms, documents, plans, manuals, procedures - inadequate/incomplete
Reports
Inspections and engineering certification
Training: inadequate/not done
AVG PEN
$18,619
$1,887
$9,769
$2,250
$1,225
$231,468
$3,593
$3,300
$36,400
$600
$1,962
C-6
-------
Summary of RCRA Administrative Orders - DOE
Facility
DOEplriejlfis /
Plant ',", •',- ! "- •',
DOE Pinellas
Plant
Lawrence
Ltvermore
Lawrence
Livermore
Lawrence
Livermore
Lawrence
Livermore
Lawrence
Livermore
Lawrence
Livermore
Lawrence
Livermore
Lawrence
Livermore
Lawrence
Livermore
Region State Dept Docket #
, 04 ,; JlflL DOE None ,
04 FL DOE None
09 CA DOE DO 93/94 2-
001
09 CA DOE. DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
Penalty
0
1
0
1
2
3
4
5
6
7
8
Forms, documents, Closure and post
plans, manuals, closure plans
procedures -
Inadequate or
incomplete
Storage and Storage not in
accumulation issues accordance with
recognized standards
for incompatibility.
Security and Safety Failure to take safety-
precautions
Unpermitted and TSD of HW without
unauthorized activity permit or interim status
Unpermitted and Unpermitted activities,
unauthorized activity or equipment, within a
permitted program
Unpermitted and Unpermitted activities,
unauthorized activity or equipment, within a
permitted program
Storage and Storage beyond
accumulation issues permitted time limits
Reports Failure to file
exception reports
Manifest and Failure to
transport problems, prepare/improper/illegi
LDR certification ble preparation of the
manifest.
$0 2/1/94 Final $1,100
$0
$0 7/23/93 Final $38,000
$0
$0
$0
$0
$0
$0
$0
$0
4/18/94 $1,100 1994 State
$0 1994 State
9/28/93 $18,000 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 Stale
$0 1993 Slate
$0 1993 Slate
$0 1993 State
C-6-1
-------
Summary of RCRA Administrative Orders - DOE (cont.)
Facility
Lawrence
Livermorc
Lawrence
Livennore
Lawrence
Livennore
Lawrence
Livermore
Lawrence
Livermore
Lawrence
Livermore
Lawrence
Livermore
Lawrence
Livermore
Lawrence
Livermore
Lawrence
Livermore
Region State Dept Docket #
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
09 CA DOE DO 93/94 2-
001
Count
9
10
11
12
13
14
15
16
17
18
Violation Violation
Category Description
Record submissions Failure to maintain or
(incomplete or late) provide records
General O&M Incomplete or failure
failures to make HW
determination
Record submissions Inadequate (raining
(incomplete or late) records
Forms, documents, Contingency plans
plans, manuals,
procedures -
inadequate or
incomplete
Labeling deficiencies Failure to label or
improperly labeled
containers
Storage and Failure to indicate
accumulation issues accumulation or
storage start dates on
containers
Labeling deficiencies Failure to label or
Improperly labeled
containers
Record submissions Failure to maintain or
(incomplete or late) provide records
Inspections and Failure to perform, or
engineering inadequate inspections
certification required in permits or
by Federal/state/local
regulations.
Unpermitted and Noncompliance with
unauthorized activity permit conditions
Violation Issue
Penalty Date
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 Slate
$0 1993 State
C-6-2
-------
Summary of RCRA Administrative Orders - DOE (cont.)
Facility Region
Lawrence ' >••", 09
Livemiore
Lawrence 09
Livermore
Los Alamos :, : 06
,<'<.''<"<
Los Alamos 06
Los Alamos 06
Los Alamos 06
Los Alamos 06
Los Alamos 06
Los Alamos 06
Los Alamos 06
Los Alamos 06
Los Alamos 06
State Dept Docket # Count Violation Violation Violation Issue Status Total SEPS Settle Amount
Category Description Penalty Date Proposed Date Paid
CA DOB HWCA 92/93-
,-;,/, , 031
CA DOE HWCA 92/93-
031
NM, , DOE NMHWA 93-
03,04
NM DOE NMHWA 93-
03,04
NM DOE NMHWA 93-
03,04
NM DOE NMHWA 93-
03,04
NM DOE NMHWA 93-
03,04
NM DOE NMHWA 93-
03,04
NM DOE NMHWA 93-
03,04
NM DOE NMHWA 93-
03,04
NM DOE NMHWA 93-
03,04
NM DOE NMHWA 93-
03,04
0
1
0
1
2
3
4
5
6
7
8
9
• - -
Unpermitted and TSD of HW without
unauthorized activity permit or interim status
Unpermitted and Unpermitted activities,
unauthorized activity or equipment, within a
permitted program
Unpermitted and Unpermilted activities,
unauthorized activity or equipment, within a
permitted program
Unpermitted and Unpermitted activities,
unauthorized activity or equipment, within a
permitted program
General O&M Use of defective
failures containers
General O&M Use of defective
failures containers
Storage and Storage beyond
accumulation issues permitted time limits
Storage and Storage beyond
accumulation issues permitted time limits
Storage and Storage beyond
accumulation issues permitted time limits
General O&M Failure to close
failures hazardous waste
(HW) containers
Penalty
$0 9/20/93 Final $9,000
$9,000
$0 1/28/93 Final $1,636,105
$381,250
$381,250
$381,250
$139,750
$121,750
$44,950
$44,950
$44,950
$550
9/20/93 $9,000
$0
12/10/93 $700,000
$0
$0
$0
$0
$0
$0
$0
$0
$0
Year
Issued
1993
1993
1993
1993
1993
1993
1993
1993
1993
1993
1993
1993
Issued
By
State
State
State
State
State
State
State
State
Slate
State
State
State
C-6-3
-------
Summary of RCRA Administrative Orders - DOE (cont.)
Facility
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Region State Dept Docket #
06 NM DOE NMHWA 93-
03,04
06 NM DOE NMHWA 93-
03,04
06 NM DOE NMHWA 93-
03,04
06 NM DOE NMHWA 93-
03,04
06 NM DOE NMHWA 93-
03,04
06 NM DOE NMHWA 93-
03,04
06 NM DOE NMHWA 93-
03,04
06 NM DOE NMHWA 93-
03,04
06 NM DOE NMHWA 93-
03,04
06 NM DOE NMHWA 93-
Count
10
11
12
13
14
15
16
17
18
19
Violation Violation
Category Description
Labeling deficiencies Failure to label or
improperly labeled
containers
Labeling deficiencies Failure to label or
improperly labeled
containers
General O&M Failure to close
failures hazardous waste
(HW) containers
Labeling deficiencies Failure to label or
improperly labeled
containers
Labeling deficiencies Failure to label or
improperly labeled
containers
Labeling deficiencies Failure to label or
improperly labeled
containers
Labeling deficiencies Failure to label or
improperly labeled
containers
Labeling deficiencies Failure to label or
improperly labeled
containers
Labeling deficiencies Failure to label or
improperly labeled
containers
Storage and Storage of HW in
Violation Issue
Penalty Date
$625
$5,100
$550
$675
$675
$675
$675
$675
$675
$600
Status Total SEPS Settle Amount
Proposed Date Paid
Penalty
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Year
Issued
1993
1993
1993
1993
1993
1993
1993
1993
1993
1993
Issued
By
State
State
State
State
Slate
Stale
State
State
State
State
03,04
accumulation issues areas not identified by
permit
C-6-4
-------
Summary of RCRA Administrative Orders - DOE (cont.)
Facility
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos ,
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Region State Dept Docket #
06 NM DOE NMHWA93-
03,04
06 NM DOE NMHWA93-
03,04
06 NM DOE NMHWA93-
03,04
06 NM DOE NMHWA93-
03,04
06 NM DOE NMHWA93-
03,04
,06 NM ! DOB NMHWA94^
09
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
Count Violation Violation Violation Issue Status Total SEPS
Category Description Penalty Date Proposed
Penalty
20 Security and Safety Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
21 Record submissions Inadequate training
(incomplete or late) records
22 Reports Failure to file
exception reports
23 Reports Failure to file
exception reports
24 Labeling deficiencies Failure to label or
improperly labeled
containers
o, •'';'"•
1 Unpermitted and TSD of HW without
unauthorized activity permit or interim status
2 Labeling deficiencies Failure to label or
improperly labeled
containers
3 General O&M Incomplete or failure
failures to make HW
determination
4 General O&M Incomplete or failure
failures to make HW
determination
5 General O&M Incomplete or failure
failures to make HW
determination
$3,740
$3,400
$36,400
$36,400
$4,590
$0 9/2/94 Neg $247,177
$4,590
$4,760
$11,340
$12,758
$131,490
Settle Amount Year Issued
Date Paid Issued By
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 Stale
$0 1993 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
C-6-5
-------
Summary of RCRA Administrative Orders - DOE (com.)
Facility
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Region State Dept
06 NM DOE
06 NM DOE
06 NM DOE
06 NM DOE
06 NM DOE
06 NM DOE
06 NM DOE
06 NM DOE
Docket #
NMHWA94-
09
NMHWA94-
09
NMHWA94-
09
NMHWA94-
09
NMHWA94-
09
NMHWA94-
09
NMHWA94-
09
NMHWA94-
09
Count Violation
Category
6 General O&M
failures
7 General O&M
failures
8 General O&M
failures
9 Manifest and
transport problems,
LDR certification
10 Security and Safety
1 1 Security and Safety
12 Security and Safety
13 Security and Safety
Violation
Description
Incomplete or failure
to make HW
determination
Incomplete or failure
to make HW
determination
Incomplete or failure
to make HW
determination
Failure to
prepare/improper/illegi
ble preparation of the
manifest.
Failure to
provide/maintain
equipment to be
utilized In response to
emergencies
Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Violation Issue
Penalty Date
$12,285
$10,867
$4,080
$11.340
$1,012
$1.013
$675
$675
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
C-6-6
-------
Summary of RCRA Administrative Orders - DOE (cont.)
Facility
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Region State Dept Docket #
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
Count Violation Violation
Category Description
14 General O&M Failure to close
failures hazardous waste
(HW) containers
1 5 General O&M Failure to close
failures hazardous waste
(HW) containers
16 Labeling deficiencies Failure to label or
improperly labeled
containers
17 Labeling deficiencies Failure to label or
improperly labeled
containers
18 Storage and Storage beyond
accumulation issues permitted volume
19 General O&M Poor or little control at
failures landfill, accumulation
point, etc.
20 Training: Inadequate training or
inadequate/not done failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
' 21 Storage and Failure to indicate
accumulation issues accumulation or
storage start dates on
containers
22 Storage and Failure to indicate
accumulation issues accumulation or
storage start dates on
containers
Violation Issue
Penalty Date
$700
$750
$8,990
$1,470
$780
$12,757
$4,590
$1,365
$1,365
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1994 State
$0 1994 Slate
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 State
$0 1994 Slate
$0 1994 State
$0 1994 Slate
C-6-7
-------
Summary of RCRA Administrative Orders - DOE (cont.)
Facility Region State Dept Docket #
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos 7 ,;" - „
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
06 NM DOE NMHWA94-
09
. 06 ,,/' > \Nty ,, DOB NMHWA95?
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
Count Violation
Category
23 Storage and
accumulation issues
24 Storage and
accumulation issues
25 Manifest and
transport problems,
LDR certification
26 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
'"V ':/.Vv..;;;
1 Labeling deficiencies
2 Labeling deficiencies
3 Labeling deficiencies
4 Labeling deficiencies
5 Labeling deficiencies
Violation Violation Issue Status Total SEPS
Description Penalty Date Proposed
Penalty
Failure to indicate
accumulation or
storage start dates on
containers
Failure to indicate
accumulation or
storage start dates on
containers
LDR notification
failure
Waste analysis plans
cW,"
Failure to label or
improperly labeled
containers
Failure to label or
improperly labeled
containers
Failure to label or
improperly labeled
containers
Failure to label or
improperly labeled
containers
Failure to label or
improperly labeled
containers
$1,365
$780
$2,080
$3,300
$0 3/22/95 Neg $103,539
$2,240
$700
$1,470
$1,470
$1,470
Settle Amount Year Issued
Date Paid Issued By
$0 1994 State
$0 1994 Slate
$0 1994 Slate
$0 1994 State
$0 1995 State
$0 1995 Stale
$0 1995 Slate
$0 1995 Slate
$0 1995 Slate
$0 1995 Slate
C-6-8
-------
Summary of RCRA Administrative Orders - DOE (cont.)
Facility
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Region State Dept Docket #
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
Count
6
7
8
9
10
11
12
13
14
15
Violation
Category
General O&M
failures
General O&M
failures
General O&M
failures
General O&M
failures
General O&M
failures
General O&M
failures
General O&M
failures
General O&M
failures
General O&M
failures
Labeling deficiencies
Violation
Description
Incomplete or failure
to make HW
determination
Incomplete or failure
to make HW
determination
Incomplete or failure
to make HW
determination
Incomplete or failure
to make HW
determination
Failure to close
hazardous waste
(HW) containers
Failure to close
hazardous waste
(HW) containers
Failure to close
hazardous waste
(HW) containers
Poor or little control at
landfill, accumulation
point, etc.
Poor or little control at
landfill, accumulation
point, etc.
Failure to label or
improperly labeled
containers
Violation Issue
Penalty Date
$3,037
$1,522
$10,150
$52,780
$725
$725
$1,087
$1,087
$1,522
$625
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1995 State
$0 1995 State
$0 1995 State
$0 1995 State
$0 1995 Slate
$0 1995 State
$0 1995 Slate
$0 1995 Slate
$0 1995 State
$0 1995 State
C-6-9
-------
Summary of RCRA Administrative Orders - DOE (cont.)
Facility
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Los Alamos
Region State Dept Docket #
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
06 NM DOE NMHWA95-
03
Count Violation Violation Violation Issue
Category Description Penalty Date
1 6 Labeling deficiencies Failure to label or $625
Improperly labeled
containers
17 Storage and Failure to Indicate $600
accumulation issues accumulation or
storage start dates on
containers
18 Storage and Failure to indicate $1,260
accumulation issues accumulation or
storage start dates on
containers
19 Security and Safety Failure to $15,950
provide/maintain
equipment to be
utilized in response to
emergencies
20 Security and Safety Failure to $870
provide/maintain
equipment to be
utilized in response to
emergencies
21 Security and Safety Failure to $870
provide/maintain
equipment to be
utilized in response to
emergencies
22 Storage and Failure to indicate $1,522
accumulation issues accumulation or
storage start dates on
containers
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1995 State
$0 1995 State
$0 1995 State
$0 1995 State
$0 1995 State
$0 1995 Slate
$0 1995 State
C-6-10
-------
Summary of RCRA Administrative Orders - DOE (cont.)
Facility
Los Alamos
Nevada Ops
Office '
Nevada Ops
Office
Nevada Ops
Office
Nevada Ops
Office
Nevada Ops
Office
Nevada Ops
Office
Nevada Ops
Office
Nevada Ops
Office
Region State Dept Docket # Count Violation Violation Violation Issue
Category Description Penalty Date
06 NM DOE NMHWA95- 23 Training: Inadequate training or $870
03 inadequate/not done failure to train
environmental staff in
the performance of
their duties as
specified by
Fcdcra I/state/local
requirements.
,09 • NV DOE None Q $0 3/10/95
09 NV DOE None 1 General O&M Failure to containerize $0
failures Hazardous Waste
09 NV DOE None 2 Storage and Failure to indicate $0
accumulation issues accumulation or
storage start dates on
containers
09 NV DOE None 3 Labeling deficiencies Failure to label or $0
improperly labeled
containers
09 NV DOE None 4 General O&M Lack of proper aisle $0
failures space in storage areas
09 NV DOE None 5 Record submissions Operating records of $0
(incomplete or late) open burning/open
detonation and other
TSD operations
09 NV DOE None 6 Inspections and Failure to perform, or $0
engineering inadequate inspections
certification required in permits or
by Federal/state/local
regulations.
09 NV DOE None 7 Storage and Storage of HW $0
accumulation issues without interim status
or permit
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1995 State
Neg $135,000 $0 1995 State
$0 1995 State
$0 1995 Slate
$0 1995 State
$0 1995 Slate
$0 1995 State
$0 1995 State
$0 1995 Stale
C-6-11
-------
Summary of RCRA Administrative Orders - DOE (cont.)
Facility
Nevada Ops
Office
Nevada Ops
Office
«»&•>
Sandia NL
Sandia NL
SandiaNi^
Sandia NL
Sandia NL
Sandia NL
Sandia NL
Region State Dept
09 NV DOE
09 NV DOE
}'<> :V$ „ , \t tf&U*' DOB
06 NM DOE
06 NM DOE
,V; , 06 "' / _ 'NM, DOB
06 NM DOE
06 NM DOE
06 NM DOE
06 NM DOE
Docket # Count
None 8
None 9
NMtJWAJi^v,'" Q*,t
NMHWA93- 1
06
NMHWA93- 2
06
SVYA^' ^
NMHWA93- 1
18
NMHWA93- 2
18
NMHWA93- 3
18
NMHWA93- 4
18
Violation
Category
Record submissions
(incomplete or late)
Labeling deficiencies
General O&M
failures
Security and Safety
,'
General O&M
failures
General O&M
failures
Inspections and
engineering
certification
Security and Safety
Violation Violation Issue
Description Penalty Date
Failure to maintain or $0
provide records
Failure to label or $0
improperly labeled
containers
$0 4/12/93
Incomplete or failure $ 1 ,360
to make HW
determination
Failure to operate in a $1,360
way that minimizes
fire or HW release
.,',' < '. W 9/8/93
Failure to close $2,400
hazardous waste
(HW) containers
Failure to close $1,575
hazardous waste
(HW) containers
Failure to perform, or $600
inadequate inspections
required in permits or
by Federal/state/local
regulations.
Failure to $1,155
provide/maintain
equipment to be
utilized in response to
emergencies
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
$0 1995
$0 1995
Final $2,720 $24,378 10/29/93 $0 1993
$0 1993
$0 1993
Final $8,843 10/14/93 $8,843 1993
$0 1993
$0 1993
$0 1993
$0 1993
Issued
By
State
State
state
State
State
State
Slate
State
State
State
C-6-12
-------
Summary of RCRA Administrative Orders - DOE (cont.)
Facility
Sandia ML
Sandia NL
Sandia NL
Sandia NL
Sandia NL
Sandia NL
Sandia NL
Sandia NL
Sandia NL
Region State Dept Docket #
06 NM DOE NMHWA93-
18
06 NM DOE NMHWA93-
18
06 NM DOE NMHWA93-
18
06 NM DOE NMHWA93-
18
06 NM DOE NMHWA94-
, 08
06 NM DOE NMHWA94-
08
06 NM DOE NMHWA94-
08
06 NM DOE NMHWA94-
08
06 NM DOE NMHWA94-
08
Count Violation Violation Violation Issue
Category Description Penalty Date
5 Training: Inadequate training or $425
Inadequate/not done failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
6 Storage and Failure to indicate $1,418
accumulation issues accumulation or
storage start dates on
containers
7 Storage and Failure to indicate $720
accumulation issues accumulation or
storage stan dates on
containers
8 Manifest and Notification failure of $550
transport problems, treatment standards
LDR certification
0 $0 10/6/94
1 Storage and Failure to indicate $17,980
accumulation issues accumulation or
storage start dates on
containers
2 General O&M Incomplete or failure $52,780
failures to make HW
determination
3 General O&M Incomplete or failure $1,087
failures to make HW
determination
4 General O&M Incomplete or failure $1,522
failures to make HW
determination
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
Neg $83,874 $0 1994 State
« — - — . — - — -
$0 1994 State
$0 1994 State
$0 1994 Slate
$0 1994 State
C-6-13
-------
Summary of RCRA Administrative Orders - DOE (com.)
Facility
Sandia NL
Sandia NL
Sandia NL
Sandia NL
Sandia NL
Sandia NL
Sandia NL
Sandia NL
Sandia NL
Region State Dept Docket #
06 NM DOE NMHWA94-
08
06 NM DOE NMHWA94-
08
06 NM DOE NMHWA94-
08
06 NM DOE NMHWA94-
08
06 NM DOE NMHWA94-
08
06 NM DOE NMHWA94-
08
06 NM DOE NMHWA94-
08
06 NM DOE NMHWA94-
08
06 NM DOE NMHWA94-
08
Count Violation
Category
S Security and Safety
6 Security and Safety
7 Security and Safety
8 General O&M
failures
9 General O&M
failures
10 General O&M
failures
1 1 Labeling deficiencies
12 Labeling deficiencies
13 Storage and
accumulation Issues
Violation
Description
Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Poor or little control at
landfill, accumulation
point, etc.
Poor or little control at
landfill, accumulation
point, etc.
Failure to close
hazardous waste
(HW) containers
Failure to label or
Improperly labeled
containers
Failure to label or
improperly labeled
containers
Storage beyond
permitted volume
Violation Issue
Penalty Date
$1,260
$1,260
$1,260
$1,260
$625
$725
$725
$725
$1,365
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1994 Slate
$0 1994 Stale
$0 1994 Slate
$0 1994 State
$0 1994 State
$0 1994 Slate
$0 1994 State
$0 1994 State
$0 1994 State
C-6-14
-------
Summary of RCRA Administrative Orders - DOE (cont.)
Facility Region
Sanciia NL 06
Sandia NL 06
Sanclia-Llvcrmore 09
Sandia-Livennore 09
Sandia-Livcnnore 09
Sandia-Livermore 09
Sandia-Livermore 09
Sandia-Livermore 09
Sandia-Livermore 09
State Dept
NM DOE
NM DOE
CA , DOE
CA DOE
CA DOE
CA DOE
CA DOE
CA DOE
CA DOE
Docket #
NMHWA94-
08
NMHWA94-
08
FO 93/94 2-
002
FO 93/94 2-
002
FO 93/94 2-
002
FO 93/94 2-
002
FO 93/94 2-
002
FO 93/94 2-
002
FO 93/94 2-
002
Count Violation
Category
14 Record submissions
(incomplete or late)
IS Record submissions
(incomplete or late)
0
1 General O&M
failures
2 Security and Safety
3 Manifest and
transport problems,
LDR certification
4 Record submissions
(incomplete or late)
5 Storage and
accumulation issues
6 General O&M
failures
Violation Violation Issue
Description Penalty . Date
Failure to maintain or $650
provide records
Inspection logs $650
$0 8/10/93
Failure to close $200
hazardous waste
(HW) containers
Failure to $400
provide/maintain
equipment to be
utilized in response to
emergencies
Notification failure of $400
treatment standards
Inspection logs $200
Failure to indicate $ 1 00
accumulation or
storage start dates on
containers
Lack of proper aisle $0
space in storage areas
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
$0 1994
$0 1994
Final $1,800 2/10/94 $1,700 1993
$0 1993
$0 1993
$0 1993
$0 1993
$0 1993
$0 1993
Issued
By
State
Stale
State
State
State
State
State
State
State
C-6-15
-------
SUMMARY OF RCRA ADMINISTRATIVE ORDERS
DOI
DOI VIOLATION SUMMARY (2nd level)
VIOLATION CATEGORY
44
45
49
72
83
48
41
47
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
5
3
3
2
1
1
1
1
17
DESCRIPTION OF VIOLATION
Storage and accumulation issues
General O&M failures
Inspections and engineering certification
Security and Safety
Not in accordance with closure plans
Nonlisted waste activities
Unpermitted and unauthorized activity
Mainfest and transport problems
AVG PEN
$135,385
$2,433
$300
$450
$500
$95,420
$600
NA
C-7
-------
Summary of RCRA Administrative Orders - DOI
Facility Region
Ft. Defiance • 09
Fl. Defiance 09
Ft. Defiance 09
Ft. Defiance 09
Hawaii Volcanoes 09
Hawaii Volcanoes 09
Hawaii Volcanoes 09
Yoscinite - 09 .
National Park
Yoscmilc 09
National Park
Yoscmite 09
National Park
Yoscmite 09
National Park
State Dept Docket #
AZ;. DOI RCRA 09 95 :
0004
AZ DOI RCRA 09 95
0004
AZ DOI RCRA 09 95
0004
AZ DOI RCRA 09 95
0004
HI DOI RCRA 09 95
0002
HI DOI RCRA 09 95
0002
HI DOI RCRA 09 95
0002
CA DOI 93/94-6003
CA DOI 93/94-6003
CA DOI 93/94-6003
CA DOI 93/94-6003
Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
Penalty
0
1
2
3
0
1
2
0
1
2
3
$0 9/27/95 Neg $269,019
Storage and Storage of HW $ 1 52,700
accumulation issues without interim status
or permit
Storage and Storage beyond $20,899
accumulation issues permitted time limits
Restricted/Nonlisted Hazardous waste $95,420
waste activities stream activities that
do not appear on
notification of
hazardous waste
activity forms
' $0 12/6/95 Neg $243,800
Storage and Storage of HW $237,300
accumulation issues without interim status
or permit
General O&M Use of defective $6,500
failures containers
$0 8/2/93 Final $3,400
Unpermitted and TSD of HW without $600
unauthorized activity permit or interim status
Security and Safety Failure to operate in a $500
way that minimizes
fire or HW release
Security and Safety Failure to $400
provide/maintain
equipment to be
utilized in response to
emergencies
$0 1995 EPA
$0 1995 EPA
$0 1995 EPA
$0 1995 EPA
$0 1995 EPA
$0 1995 EPA
$0 1995 EPA
7/8/94 $2,250 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 State
C-7-1
-------
Summary of RCRA Administrative Orders - DOI (cont.)
Facility Region State Dept Docket* Count
Yosemite 09 CA DOI 93/94-6003 4
National Park
Yosemite 09 CA DOI 93/94-6003 5
National Park
Yosemite 09 CA DOI 93/94-6003 6
National Park
Yosemite 09 CA DOI 93/94-6003 7
National Park
Yosemite 09 CA DOI 93/94-6003 8
National Park
Yosemite-, • Of ••">' '"-"'0, T* i ITCAl1 •"•,'EN5l , ?3/94-i55,d2v, '.'<•: 0 .; '
National Park §;//>y^^ -;:'•' ;
Yosemite 09 CA DOI 93/94-6502 1
National Park
Yosemite 09 CA DOI 93/94-6502 2
National Park
Violation
Category
General O&M
failures
General O&M
failures
Inspections and
engineering
certification
Inspections and
engineering
certification
Not in accordance
with closure plans
'?vSfe3
Manifest and
transport problems,
LDR certification
Inspections and
engineering
certification
Violation Violation Issue
Description Penalty Date
Use of defective $600
containers
Failure to close $200
hazardous waste
(HW) containers
Failure to perform, or $300
inadequate Inspections
required in permits or
by FederaVstate/local
regulations.
Failure to perform, or $300
inadequate inspections
required In permits or
by Federal/state/local
regulations.
Violations resulting $500
when closure of
specific operational
units and structures is
not completed
according to closure
plan specifications or
requirements.
j.^V;^ .;. ;v *•:*'.**".
LDR certification $0
requirements.
Failure to perform, or $0
inadequate inspections
required in permits or
by Federal/statc/local
regulations.
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
$0 1993
$0 1993
$0 1993
$0 1993
$0 1993
Final $2,000 7/8/94 $2,000 1993
$0 1993
$0 1993
Issued
By
State
Slate
State
State
State
State
State
State
C-7-2
-------
Summary of RCRA Administrative Orders - DOI (cont.)
Facility Region State Dept Docket # Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
Penalty
YumaDaSsUlng ,: 09, : -AZ DO^ RCRA 09 95; - 0
Plant < ',•'- '•- '-,' ' -.' - -- - : ",-0003-,,,' •'/ ' '
$0 8/22/95 Neg $266,025
$0
1995 EPA
Yuma DeSalting 09
Plant
AZ DOI RCRA0995 1 Storageand SlorageofHW $245,126
0003 accumulation issues without interim status
or permit
$0
1995 EPA
Yuma DeSalting 09 AZ DOI RCRA 09 95 2 Storageand Storage beyond $20,899
Plant 0003 accumulation Issues permitted time limits
$0
1995 EPA
C-7-3
-------
SUMMARY OF RCRA ADMINISTRATIVE ORDERS
USMC
USMC VIOLATION SUMMARY (2nd level)
VIOLATION CATEGORY
44
47
45
43
42
63
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
4
2
2
2
2
1
13
DESCRIPTION OF VIOLATION
Storage and accumulation issues
Manifest and transport problems, LDR certification
General O&M failures
Labeling deficiencies
Record submissions (incomplete or late)
Hazardous waste treatment, storage or disposal
AVG PEN
NA
NA
$800
$1,000
$300
NA
C-8
-------
Summary of RCRA Administrative Orders - USMC
Facility Region
MC LogisliCS 09
Base
MC Logistics 09
Base
MC Logistics 09
Base
MC Logistics 09
Base
MCASElTorO 09
MCASElToro 09
MCAS El Toro 09
MCAS El Toro 09
MCAS El Toro 09
MCAS El Toro 09
MCAS El Toro 09
MCAS El Toro 09
State Dept Docket # Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
Penalty
CA USMC FO 92/93 42 12
CA USMC FO 92/93 42 12
CA USMC FO 92/93 42 12
CA USMC FO 92/93 42 12
CA USMC HWCA 92/93-
', 041
CA USMC HWCA 92/93-
041
CA USMC HWCA 92/93-
041
CA USMC HWCA 92/93-
041
CA USMC HWCA 92/93-
041
CA USMC HWCA 92/93-
041
CA USMC HWCA 92/93-
041
CA USMC HWCA 92/93-
041
0 $0 2/25/93 Neg $2,100
1 Labeling deficiencies Failure to label or $ 1 ,000
improperly labeled
containers
2 Record submissions Inadequate training $300
(incomplete or late) records
3 General O&M Failure to close $800
failures hazardous waste
(HW) containers
0 $0 4/26/93 Final $80,500
1 Manifest and Failure to $0
transport problems, prepare/improper/illegi
LDR certification ble preparation of the
manifest.
2 Manifest and LDR notification $0
transport problems, failure
LDR certification
3 Storage and Storage beyond $0
accumulation issues permitted volume
4 Record submissions Inspection logs $0
(incomplete or late)
5 Labeling deficiencies Failure to label or $0
improperly labeled
containers
6 Storage and Storage beyond $0
accumulation issues permitted time limits
7 General O&M Failure to close $0
failures hazardous waste
(HW) containers
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
10/18/94 $42,000 1993 State
$0 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 Slate
C-8-1
-------
Summary of RCRA Administrative Orders - USMC (com.)
Facility Region State Dept Docket # Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
—————_____-__^ Penalty
MCASElToro 09 CA USMC HWCA 92/93- 8 Storage and Storage not in
041 accumulation issues accordance with
recognized standards
for incompatibility.
$0
$0 1993 State
MCASElToro 09 CA USMC HWCA 92/93- 9 Hazardous waste Design deficiencies for
041 treatment, storage or HWTSD facility -
disposal Lack of secondary
containment
$0
$0 1993 Stale
MCASElToro 09 CA USMC HWCA 92/93- 10 Storage and Failure to indicate
041 accumulation issues accumulation or
storage start dates on
containers
$0
$0 1993 Slate
C-8-2
-------
SUMMARY OF RCRA ADMINISTRATIVE ORDERS
NASA
NASA VIOLATION SUMMARY (2nd level)
VIOLATION CATEGORY
72
43
41
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
8
2
1
11
DESCRIPTION OF VIOLATION
Security and Safety
Labeling deficiencies
Unpermitted and unauthorized activity
AVG PEN
$450
$400
$9,000
C-9
-------
Summary of RCRA Administrative Orders - NASA
Facility
Edwards AFB
Edwards AFB
Edwnrds AFB
Edwards AFB
Edwards AFB
Edwards AFB
Edwards AFB
Edwards AFB
Edwards AFB
Edwards AFB
Edwards AFB
Region State Dept Docket #
09 CA; NASA 92/93-027
09 CA NASA 92/93-027
'. 09 CA, : NASA 92/93-6010
09 CA NASA 92/93-6010
09 CA NASA 92/93-6010
09 CA NASA 92/93-6010
09 CA NASA 92/93-6010
09 CA NASA 92/93-6010
09 CA NASA FO 92/93-
6010
09 CA NASA FO 92/93-
6010
09 CA NASA FO 92/93-
6010
Count
0
1
0
1
2
3
4
5
.'. 0
1
2
Violation Violation
Category Description
Unpermitted and Failure to obtain
unauthorized activity permit/authorization
Labeling deficiencies Failure to label or
improperly labeled
containers
Security and Safety Failure to post
hazardous waste
management areas
Security and Safety Failure to operate in a
way that minimizes
fire or HW release
Security and Safely Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Security and Safety Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Labeling deficiencies Failure to label or
improperly labeled
containers
Security and Safety Failure to post
hazardous waste
management areas
Violation Issue Status Total
Penalty Date Proposed
Penalty
$0 11/24/92 Final $9,000
$9,000
$0 5/14/93 Final $2,200
$400
$500
$500
$400
$400
$0 5/14/93 Neg $2,200
$400
$500
SEPS Settle Amount
Date Paid
1/15/93 $9,000
$0
7/12/93 $2,200
$0
$0
$0
$0
$0
$0
$0
$0
Year
Issued
1992
1992
1993
1993
1993
1993
1993
1993
1993
1993
1993
Issued
By
State
State
State
State
Slate
Slate
Slate
Slate
State
Stale
Slate
C-9-1
-------
Summary of RCRA Administrative Orders - NASA (cont.)
Facility Region State Dept Docket # Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
Penalty
Edwards AFB 09 CA NASA FO 92/93- 3 Security and Safety Failure to operate in a $500
6010 way that minimizes
fire or HW release
$0 1993 State
Edwards AFB 09 CA NASA FO 92/93- 4 Security and Safety Failure to
6010 provide/maintain
equipment to be
utilized in response to
emergencies
$400
$0 1993 State
Edwards AFB 09 CA NASA FO 92/93- 5 Security and Safety Failure to
6010 provide/maintain
equipment to be
utilized in response to
emergencies
$400
$0 1993 State
C-9-2
-------
SUMMARY OF RCRA ADMINISTRATIVE ORDERS
NAVY
NAVY VIOLATION SUMMARY (2nd level)
VIOLATION CATEGORY
45
44
43
72
73
47
42
41
33
49
56
54
71
63
83
64
52
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
20
17
16
16
12
10
9
8
7
5
2
2
2
1
1
1
1
130
DESCRIPTION OF VIOLATION
General O&M failures
Storage and accumulation issues
Labeling deficiencies
Security and Safety
Forms, documents, plans, manuals, procedures - inadequate/incomplete
Manifest and transport problems, LDR certification
Record submissions (incomplete or late)
Unpermitted and unauthorized activity
Training: inadequate/not done
Inspections and engineering certification
Spills, releases, etc. not reported
Spill.leak or discharge contamination
Reports
Hazardous waste treatment, storage or disposal
Not in accordance with closure plans
Underground storage tank
Leak/spill from container/UST
AVG PEN
$17,223
$9,096
$3,350
$11,885
$32,550
$9,175
$28,653
$17,500
$28,557
9975
NA
$5,625
$300
NA
NA
NA
NA
C-10
-------
Summary of RCRA Administrative Orders - Navy
Facility
Alamcda Naval
Air Station
Alameda Naval
Air Station
Alameda Naval
Air Station
Alameda Naval
Air Station
Alameda Naval
Air Station
Alameda Naval
Air Station
Alamcda Naval
Air Station
Alameda Naval
Air Station
Alamcda Naval
Air Station
Region State Dept Docket # Count Violation Violation Violation Issue
Category Description Penalty Date
09 CA Navy FY 92/93-045 0 $0 4/30/93
09 CA Navy FY 92/93-045 1 Storage and Storage beyond $0 -
accumulation issues permitted time limits
09 CA Navy FY 92/93-045 2 Storage and Storage not in $0
accumulation issues accordance with
recognized standards
for incompatibility.
09 CA Navy FY 92/93-045 3 Labeling deficiencies Failure to label or $0
improperly labeled
containers
09 CA Navy FY 92/93-045 4 Training: Inadequate training or $0
inadequate/not done failure to train
environmental staff in
the performance of
their duties as
specified by
Fcderal/statc/local
requirements.
09 CA Navy FY 92/93-045 5 General O&M Failure to containerize $0
failures Hazardous Waste
09 CA Navy FY 92/93-045 6 General O&M Incomplete or failure $0
failu^s to make HW
determination
09 CA Navy FY 92/93-045 7 Security and Safety Failure to $0
provide/maintain
equipment to be
utilized in response to
emergencies
09 CA Navy FY 92/93-045 8 Inspections and Failure to perform, or $0
engineering inadequate inspections
certification required in permits or
by Federal/state/local
regulations.
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
Neg $122,600 $0 1993 State
$0 1993 State
$0 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 State
$0 1993 State
C-10-1
-------
Summary of RCRA Administrative Orders - Navy (com.)
Facility Region
Alaincda Naval 09
Air Station
Alameda Naval 09
Air Station
Alameda Naval 09
Air Station
Alameda Naval 09
Air Station
Alameda Naval 09
Air Station
Alameda Naval 09
Air Station
Alameda Naval 09
Air Station
Alameda Naval 09
Air Station
Alameda Naval 09
Air Station
CBCDavisviiie 01
CDC Davisville 01
State Dept Docket # Count Violation Violation Violation Issue Status Total SEPS Settle Amount Year Issued
Category Description Penalty Date Proposed Date Paid Issued By
Penalty
CA Navy FY 92/93-045 9 Manifest and Notification failure of
transport problems, treatment standards
LDR certification
CA Navy FY 92/93-045 10 Manifest and LDR notification
transport problems, failure
LDR certification
CA Navy FY 92/93-045 11 Manifest and LDR notification
transport problems, failure
LDR certification
CA Navy FY 92/93-045 12 Record submissions Inspection logs
(incomplete or late)
CA Navy FY 92/93-045 13 Labeling deficiencies Failure to label or
Improperly labeled
containers
CA Navy FY 92/93-045 14 Unpermitted and Unpermitted activities,
unauthorized activity or equipment, within a
permitted program
CA Navy FY 92/93-045 15 Forms, documents, Waste analysis plans
plans, manuals,
procedures -
inadequate or
incomplete
CA Navy FY 92/93-045 16 General O&M Lack of proper aisle
failures space in storage areas
CA Navy FY 92/93-045 17 Labeling deficiencies Failure to label or
improperly labeled
containers
RI Navy HW-93-136 0
RI Navy HW-93-136 1 Storage and Storage beyond
accumulation issues permitted time limits
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0 2/25/93 Neg $27,000
$9,000
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 State
C-10-2
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility
CBC Davisville
CBC Davisville
CBC Davisville
CBC Davisville
CBC Davisville
CBC Davisville
CBC Davisville
CBC Davisville
CBC Davisville
Region State Dept Docket # Count Violation
Category
01 RI Navy HW-93-136 2 General O&M
failures
01 RI Navy HW-93-136 3 Spill, leak or
discharge
contamination
01 RI Navy 1-93-1089 0
01 RI Navy 1-93-1089 1 General O&M
failures
01 RI Navy 1-93-1089 2 Manifest and
transport problems,
LDR certification
01 RI Navy 1-93-1089 3 Record submissions
(incomplete or late)
01 RI Navy 1-93-1089 4 Training:
inadequate/not done
01 RI Navy 1-93-1089 5 Record submissions
(incomplete or late)
01 RI Navy 1-93-1089 6 Storage and
accumulation issues
Violation Violation Issue
Description Penalty Date
Failure to containerize $9,000
Hazardous Waste
Inadequate spill $9,000 .
cleanup or remediation
$0 9/30/93
Incomplete or failure $23,362
to make HW
determination
Notification failure of $13,650
treatment standards
Land disposal $0
restriction (LDR)
certifications
Inadequate training or $23,625
failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/statc/local
requirements.
Inadequate training $23,625
records
Failure to indicate $6,825
accumulation or
storage start dates on
containers
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
$0 1993
$0 1993
Final $101,062 8/2/94 $57,223 1993
$0 1993
$0 1993
$0 1993
$0 1993
$0 1993
$0 1993
Issued
By
State
State
EPA
EPA
EPA
EPA
EPA
EPA
EPA
C-10-3
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility Region State
CBC Davisville 01 RI
Coastal Systems 04 FL
Station ' v \ ,
Coastal Systems 04 FL
Station
Coastal Systems 6^4 FL -
Station: ,' °~< v!,, V- t- ^,
Coastal Systems 04 FL
Station
Coastal Systems 04 FL
Station
Coastal Systems 04 FL
Station
Coastal Systems 04 FL
Station
Dept Docket # Count Violation
Category
Navy 1-93-1089 7 Inspections and
engineering
certification
JNavy 95-02*R ^ ,,0 . >' " , •
> i **" " * > ,, x
Violation Violation Issue Status Total
Description Penalty Date Proposed
Penalty
Failure to perform, or $9,975
inadequate Inspections
required in permits or
by Federal/state/local
regulations.
-_ ;v~ > ' $0 3/23/95 Neg $34,000
Navy 95-02-R 1 Unpermitted and Noncompliance with $34,000 3/23/95
unauthorized activity permit conditions
^M^^^.^C"Sf
Navy None 1 Record submissions
(incomplete or late)
Navy None 2 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
Navy None 3 General O&M
failures
Navy None 4 Training:
inadequate/not done
:^r;, .<.;>*;;:,-..10.,^ final $0
Land disposal $0
restriction (LDR)
certifications
Other documents $0
required in order to
have a permitted
program, but not of
themselves essential to
proper operation of
environmental
activities.
Incomplete or failure $0
to make HW
determination
Inadequate training or $0
failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
SEPS Settle Amount Year Issued
Date Paid Issued By
$0 1993 EPA
$0 1995 EPA
1995 EPA
2/3/94 $0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
$0 1993 State
C-104
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility
Coastal Systems
Station
Coastal Systems
Station
Coastal Systems
Station
Coastal Systems
Station
Coastal Systems
Station
Coastal Systems
Station
Coastal Systems
Station
Region State Dept Docket # Count Violation Violation Violation Issue
Category Description Penalty Date
04 FL Navy None 5 Leak/spill from Leaks, spills, or $0
container/UST discharges of
hazardous substances
from drums, USTs, or
other storage vessels
into the soil, surface
water, or groundwatcr.
04 FL Navy None 6 Forms, documents, Closure and post $0
plans, manuals, closure plans
procedures -
inadequate or
incomplete
04 FL Navy None 7 Unpermitted and Unperrnilled activities, $0
unauthorized activity or equipment, within a
permitted program
04 FL Navy None 8 Unpermitted and Unpermitted activities, $0
unauthorized activity or equipment, within a
permitted program
04 , FL Navy None-1 0 , $0 2/4/93
04 FL Navy None-1 1 Training: Inadequate training or $0
inadequate/not done failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
04 FL Navy None-1 2 Forms, documents, Contingency plans $0
plans, manuals,
procedures -
inadequate or
incomplete
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1993 State
$0 1993 State
$0 1993 Slate
$0 1993 State
Final $14,250 8/12/93 $0 1993 State
$0 1993 State
$0 1993 State
C-10-5
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility Region
Coastal Systems 04
Station
El Centra Natal ;; ' 09 /
Air',, H' '">''• 'Or*' ;'•„,,.
El Centra Naval 09
Air
El Centra Naval 09
Air
El Centra Naval 09
Air
El Centra Naval 09
Air
El Ccntro Naval 09
Air
State Dept Docket # Count Violation
Category
FL Navy None-1 3 Underground
storage tank
CA Navy 9-93-0007 1 General O&M
failures
CA Navy 9-93-0007 2 Manifest and
transport problems,
LDR certification
CA Navy 9-93-0007 3 Storage and
accumulation Issues
CA Navy 9-93-0007 4 Training:
•inadequate/not done
CA Navy 9-93-0007 5 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
Violation Violation Issue
Description Penalty Date
UST design $0
deficiencies or
operational capability
issues are included in
this code. Deficiencies
relative to design
requirements can be
assessed given
Federal/slate/local
regulations for USTs.
:':--'^'^''^:,^'/-^..:J-, W" 4/30/93
Incomplete or failure $5 1 ,355 4/30/93
to make HW
determination
Failure to $2,250 4/30/93
prepare/improper/illegi
ble preparation of the
manifest.
Storage not in $6,500 4/30/93
accordance with
recognized standards
for incompatibility.
Inadequate training or $33,488 4/30/93
failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
Contingency plans $32,550 4/30/93
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1993 Slate
Yes $257,580,, $283.480 8/28/94 $100,000 1993 EPA
1993 EPA
1993 EPA
1993 EPA
1993 EPA
1993 EPA
C-10-6
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility
El Centra Naval
Air
El Centra Naval
Air
El Centra Naval
Air
El Centra Naval
Air
El Centra Naval
Air
El Centra Naval
Air
El Centra Naval
Air
El Centra Naval
Air
El Centra Naval
Air
El Centre Naval
Air
El Centra Naval
Air
Region State Dept Docket #
09 CA Navy 9-93-0007
09 CA Navy 9-93-0007
09 CA Navy 9-93-0007
09 CA Navy 9-93-0007
09 CA Navy 9-93-0007
09 CA Navy 9-93-0007
09 CA Navy 9-93-0007
09 CA Navy 9-93-0007
09 CA Navy 9-93-0007
09 CA Navy 9-93-0007
09 CA Navy 9-93-0007
Count Violation
Category
6 Spill, leak or
discharge
contamination
7 Security and Safety
8 Security and Safety
9 Security and Safety
10 Storage and
accumulation issues
1 1 Storage and
accumulation issues
12 Storage and
accumulation issues
13 Labeling deficiencies
14 Reports
15 Record submissions
(incomplete or late)
16 Manifest and
transport problems,
LDR certification
Violation
Description
Failure to immediately
dispose of HW release
wastes
Failure to operate in a
way that minimizes
fire or HW release
Failure to provide
personal protection
equipment
Inadequate aisle space
for egress
Failure to properly
locate/control SAAs
Failure to properly
date containers in
SAAs
Failure to indicate
accumulation or
storage start dates on
containers
Failure to label or
improperly labeled
containers
Failure to sign
required reports
Failure to maintain or
provide records
LDR notification
failure
Violation
Penalty
$2,250
$22,511
$6,645
$6,500
$18,250
$7,500
$6,500
$6,500
$300
$33,681
$13,550
Issue
Date
4/30/93
4/30/93
4/30/93
4/30/93
4/30/93
4/30/93
4/30/93
4/30/93
4/30/93
4/30/93
4/30/93
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
1993
1993
1993
1993
1993
1993
1993
1993
1993
1993
1993
Issued
By
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
EPA
C-10-7
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility
El Centre Naval
Air
Long Beach
Naval Ship
Long Beach
Naval Ship
Long Beach
Naval Ship
Long Beach
Naval Ship
Long Beach
Naval Ship
Long Beach
Naval Ship
Long Beach
Naval Ship
Long Beach
Naval Ship
Region State Dept Docket #
09 CA Navy 9-93-0007
, 09 , CA ftavy DO 93^
••'•--• - : 4202 \- f ,,.
09 CA Navy DO 93/94-
4202
09 CA Navy DO 93/94-
4202
09 CA Navy DO 93/94-
4202
09 CA Navy DO 93/94-
4202
09 CA Navy DO 93/94-
4202
09 CA Navy DO 93/94-
4202
09 CA Navy DO 93/94-
4202
Count
17
-:v -0 ,
i
2
3
4
5
6
7
Violation
Category
Manifest and
transport problems,
LDR certification
< ' (v
Security and Safety
Security and Safety
General O&M
failures
Storage and
accumulation issues
Labeling deficiencies
Inspections and
engineering
certification
Record submissions
(incomplete or late)
Violation Violation Issue
Description Penalty Date
LDR certification $7,250 4/30/93
requirements.
, ' $0 3/4/94
Failure to $0
provide/maintain
equipment to be
utilized in response to
emergencies
Failure to $0
provide/maintain
equipment to be
utilized in response to
emergencies
Failure to close $0
hazardous waste
(liW) containers
Failure to indicate $0
accumulation or
storage start dates on
containers
Failure to label or $0
improperly labeled
containers
Failure to perform, or $0
inadequate inspections
required in permits or
by Federal/state/local
regulations.
Failure to maintain or $0
provide records
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
1993
. Final $23,575 6/1/94 $23,575 1994
$0 1994
$0 1994
$0 1994
$0 1994
$0 1994
$0 1994
$0 1994
Issued
By
EPA
State
State
State
State
Slate
State
State
State
C-10-8
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility
Long Beach
Naval Ship
Long Beach
Naval Ship
Long Beach
Naval Ship
Mare Island
Naval Ship
Marc Island
Naval Ship
Mare Island
Naval Ship
Mare Island
Naval Ship
Mare Island
Naval Ship
Mare Island
Naval Ship
Region State Dept
09 CA Navy
09 CA Navy
09 CA Navy
09 CA Navy
09 CA Navy
09 CA Navy
09 CA Navy
09 CA Navy
09 CA Navy
Docket #
DO 93/94-
4202
DO 93/94-
4202
DO 93/94-
4202
DO 93/94-2-
004
DO 93/94-2-
004
DO 93/94-2-
004
DO 93/94-2-
004
DO 93/94-2-
004
DO 93/94-2-
004
Count Violation
Category
8 Spills, releases, etc.
not reported
9 Storage and
accumulation issues
10 Labeling deficiencies
0
1 Labeling deficiencies
2 General O&M
failures
3 Security and Safety
4 Manifest and
transport problems,
LDR certification
5 Training:
inadequate/not done
Violation Violation Issue
Description Penalty Date
Spills, releases, etc., $0
that are not reported in
a timely manner as
defined by regulation.
Storage of HW in $0
areas not identified by
permit
Failure to label or $0
improperly labeled
containers
$0 7/16/93
Failure to label or $0
improperly labeled
containers
Failure to close $0
hazardous waste
(HW) containers
Failure to $0
provide/maintain
equipment to be
utilized in response to
emergencies
LDR notification $0
failure
Inadequate training or $0
failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
$0 1994
$0 1994
$0 1994
Final $10,800 3/16/95 $10,800 1993
$0 1993
$0 1993
$0 1993
$0 1993
$0 1993
Issued
By
State
State
Slate
State
State
Slate
State
Stale
State
C-10-9
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility Region State
NAS tioca Chtco 04, ,/FL
NAS Boca Chico 04 FL
NAS Boca Chico 04 FL
NAS Boca Chico 04 FL
NAS Boca Chico 04 FL
NAS^^',^;V^i
NAS Boca Chico 04 FL
NAS Boca Chico 04 FL
NAS Boca Chico 04 FL
NAS North ' ' ?? 09 - CA
Island San -; , ;, - -
NAS North 09 CA
Island San
Dept Docket # Count Violation
Category
Navy None'; "• " ' '"£',0 ' •
Navy None 1 Storage and
accumulation issues
Navy None 2 General O&M
failures
Navy None 3 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
Navy None 4 General O&M
failures
:,«fN$vy; 1 fyoneji ;/;;<>,• orth,0', • •'", ; "-^ ',. ,"-;•;<•''';-
Navy None-1 1 Storage and
accumulation issues
Navy None-1 2 Security and Safety
Navy None-1 3 Security and Safety
Navy FO 93/94. .•••'• t> ' . '>•' •
', , 4152 „- '
Navy FO 93/94- 1 Labeling deficiencies
4152
Violation
Description
Failure to indicate
accumulation or
storage start dates on
containers
Incomplete or failure
to make HW
determination
Waste analysis plans
Failure to close
hazardous waste
(HW) containers
' ,''''?>• a>~ :.'~ ":
Storage beyond
permitted time limits
Failure to post
hazardous waste
management areas
Failure to operate in a
way that minimizes
fire or HW release
Failure to label or
improperly labeled
containers
Violation Issue Status Total
Penalty Date Proposed
Penalty
$0 3/24/93 Final $4,037
$0
$0
$0
$0
-;•;,,-, $0 2/8/94 Final $24,772
$0
$0
$0
$0 5/13/94 Final $600
$200
SEPS Settle Amount
Date Paid
4/12/94 $6,055
$0
$0
$0
$0
3/22/95 $0
$0
$0
$0
7/19/94 $600
$0
Year
Issued
1993
1993
1993
1993
1993
1994
1994
1994
1994
1994
1994
Issued
By
State
State
State
State
State
State
State
State
State
Slate
Slate
C-10-10
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility
NAS North
Island San
NAS North
Island San
NAS North
Island San
NAS North
Island San
NAS North
Island San
NAS North
Island San
NAS North
Island San
NAS North
Island San
NAS North
Island San
NAS North
Island San
Region State Dept Docket #
09 CA Navy FO 93/94-
4152
09 CA Navy HWCA 93/94-
008
09 CA Navy HWCA 93/94-
008
09 CA Navy HWCA 93/94-
008
09 CA Navy HWCA 93/94-
008
09 CA Navy HWCA 93/94-
008
09 CA Navy HWCA 93/94-
008
09 CA Navy HWCA 93/94-
008
09 CA Navy HWCA 93/94-
008
09 CA Navy HWCA 93/94-
008
Count Violation
Category
2 General O&M
failures
0
1 Unpermilted and
unauthorized activity
2 General O&M
failures
3 Security and Safety
4 Record submissions
(incomplete or late)
5 Not in accordance
with closure plans
6 Security and Safety
7 General O&M
failures
8 Storage and
accumulation issues
Violation Violation Issue
Description Penalty Date
Failure to close $400
hazardous waste
(HW) containers
$0 *8/10/93
Unpcrmitted activities, $0
or equipment, within a
permitted program
Improper O&M of $0
containment facility
Failure to post $0
hazardous waste
management areas
Failure to maintain or $0
provide records
Violations resulting $0
when closure of
specific operational
units and structures is
not completed
according to closure
plan specifications or
requirements.
Failure to operate in a $0
way that minimizes
fire or HW release
Failure to close $0
hazardous waste
(HW) containers
Storage not in $0
accordance with
recognized standards
for incompatibility.
Status Total SEPS Settle Amount Year
Proposed Date Paid Issued
Penalty
$0 1994
Final $49,760 6/30/95 $16,839 1993
$0 1993
$0 1993
$0 1993
$0 1993
$0 1993
$0 1993
$0 1993
$0 1993
Issued
By
State
State
State
Slate
State
State
State
State
State
State
C-10-11
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility Region
NAS North 09
Island San
NAS North 09
Island San
NAS North 09
Island San
Navy PWC San , 09 ,
Navy PWC San 09
Diego
Navy PWC San 09
Diego
Navy PWC San 09
Diego
Navy PWC San 09
Diego
State Dept Docket #
CA Navy HWCA 93/94-
008
CA Navy HWCA 93/94-
008
CA Navy HWCA 93/94-
008
CA, Navy HWCA92/93-
CA Navy HWCA 92/93-
042
CA Navy HWCA 92/93-
042
CA Navy HWCA 92/93-
042
CA Navy HWCA 92/93-
042
Count Violation Violation Violation Issue
Category Description Penalty Date
9 Forms, documents, Contingency plans $0
plans, manuals,
procedures -
inadequate or
incomplete
10 Storage and Storage beyond $0
accumulation issues permitted time limits
11 Record submissions Inspection logs $0
(incomplete or late)
v-i^l^-/.-.'-C :'•:'>'" " $° 4/26/93
1 Unpermitted and TSD of HW without $0
unauthorized activity permit or interim status
2 Unpermitted and TSD of HW without $0
unauthorized activity permit or interim status
3 Inspections and Failure to obtain $0
engineering engineering
certification certification of
structural
integrity/proper
system installation
prior to use of certain
waste management
units, such as tanks.
4 Labeling deficiencies Failure to label or $0
improperly labeled
containers
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1993 State
$0 1993 State
$0 1993 State
Neg $260,032 $0 1993 Stale
$0 1993 State
$0 1993 Slate
$0 1993 State
$0 1993 State
C-10-12
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility
Navy PWC San
Diego
Navy PWC San
Diego
Navy PWC San
Diego
NCS-Stockton
NCS-Stockton
NCS-Stockton
Region State Dept Docket #
09 CA Navy HWCA 92/93-
042
09 CA Navy HWCA 92/93-
042
09 CA Navy HWCA 92/93-
. 042
09 CA Navy HWCA 93/94-
019
09 CA Navy HWCA 93/94-
019
09 CA Navy HWCA 93/94-
019
Count Violation
Category
5 Training:
inadequate/not done
6 General O&M
failures
7 Storage and
accumulation issues
0
1 Inspections and
engineering
certification
2 Security and Safety
Violation Violation Issue Status Total
Description Penalty Date Proposed
Penalty
Inadequate training or $0
failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
Lack of proper aisle $0
space in storage areas
Failure to indicate $0
accumulation or
storage start dates on
containers
$0 12/16/94 Neg $70,000
> \
Failure to obtain $0
engineering
certification of
structural
integrity/proper
system installation
prior to use of certain
waste management
units, such as tanks.
Failure to operate in a $0
way that minimizes
fire or HW release
SEPS Settle Amount Year Issued
Date Paid Issued By
$0 1993 Slate
$0 1993 State
$0 1993 Slate
$0 1994 State
$0 1994 State
$0 1994 State
NCS-Stockton 09 CA Navy HWCA 93/94-
019
3 Spills, releases, etc. Spills, releases, etc.,
not reported (hat are not reported in
a timely manner as
defined by regulation.
$0
$0 1994 State
NCS-Stockton 09 CA Navy HWCA 93/94- 4 Reports
019
Failure to submit HW
release report in timely
manner
$0
$0 1994 Stale
C-10-13
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility
NCS-Stockton
Oakland Supply
Center ',",-.
Oakland Supply
Center
Oakland Supply
Center
Oakland Supply
Center
Oakland Supply
Center
Oakland Supply
Center
Oakland Supply
Center
Oakland Supply
Center
Oakland Supply
Center
Region State Dept Docket #
09 CA Navy HWCA 93/94-
019
.,09 CA rtavy" HWCA 92/93-
''-; r ' > '" • > 021 '";; , ';
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
Count Violation Violation
Category Description
5 Labeling deficiencies Failure to label or
improperly labeled
containers
-; 0 ,- , ' -' , ,Y; ' '
1 Hazardous waste Design deficiencies for
treatment, storage or HW TSD facility -
disposal Structural flaws in
storage areas
2 Storage and Storage beyond
accumulation issues permitted time limits
3 Labeling deficiencies Failure to label or
improperly labeled
containers
4 Labeling deficiencies Failure to label or
improperly labeled
containers
5 Labeling deficiencies Failure to label or
improperly labeled
containers
6 Labeling deficiencies Failure to label or
improperly labeled
containers
7 Storage and Storage not in
accumulation issues accordance with
recognized standards
for incompatibility.
8 Security and Safety Failure to provide
personal protection
equipment
Violation Issue Status Total SEPS
Penalty Date Proposed
Penalty
$0
$0 11/16/92 Final $2,150
$0
$0
$0
$0
$0
$0
$0
$0
Settle Amount Year
Date Paid Issued
$0 1994
11/18/92 $2,150 1992
$0 1992
$0 1992
$0 1992
$0 1992
$0 1992
$0 1992
$0 1992
$0 1992
Issued
By
State
State
State
State
State
State
State
State
State
State
C-10-14
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility
Oakland Supply
Center
Oakland Supply
Center
Oakland Supply
Center
Oakland Supply
Center
Oakland Supply
Center
Oakland Supply
Center
Oakland Supply
Center
Oakland Supply
Center
Oakland Supply
Center
Region State Dept Docket #
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
09 CA Navy HWCA 92/93-
021
Count Violation
Category
9 Security and Safety
10 General O&M
failures
1 1 General O&M
failures
12 General O&M
failures
13 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
14 Security and Safety
IS Manifest and
transport problems,
LDR certification
16 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
17 Record submissions
(incomplete or late)
Violation
Description
Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Lack of proper aisle
space in storage areas
Failure to close
hazardous waste
(HW) containers
Failure to close
hazardous waste
(HW) containers
Contingency plans
Failure to
provide/maintain
equipment to be
utilized in response to
emergencies
Untimely submittal of
manifests
Closure and post
closure plans
Inspection logs
Violation Issue
Penalty Date
$0
$0
$0
$0
$0
$0
$0
$0
$0
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1992 State
$0 1992 Slate
$0 1992 State
$0 1992 State
$0 1992 Slate
$0 1992 Stale
$0 1992 State
$0 1992 State
$0 1992 Slate
C-10-15
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility Region
Oakland Supply 09
Center
Oakland Supply 09
Center
Oakland Supply 09
Center
Port Hueneme' 09
J " "*<
Port Hueneme 09
Port Hueneme 09
Port Hueneme 09
Port Hueneme 09
State Dept Docket # Count
CA Navy HWCA 92/93- 18
021
CA Navy HWCA 92/93- 19
021
CA Navy HWCA 92/93- 20
021
< CA , ' fcavy DO 92/93' ' < ' 0 -!*
< ' ' 3009 "IA, , >, ,
j •* a£ f , < * ;
CA Navy DO 92/93- 1
3009
CA Navy DO 92/93- 2
3009
CA Navy DO 92/93- 3
3009
CA Navy DO 92/93- 4
3009
Violation
Category
Forms, documents,
plans, manuals,
procedures -
Inadequate or
incomplete
Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
Manifest and
transport problems,
LDR certification
s ' '•.
," ' •.
Security and Safety
General O&M
failures
Labeling deficiencies
Labeling deficiencies
Violation Violation Issue
Description Penalty Date
Other documents $0
required in order to
have a permitted
program, but not of
themselves essential to
proper operation of
environmental
activities.
Other documents $0
required in order to
have a permitted
program, but not of
themselves essential to
proper operation of
environmental
activities.
LDR notification $0
failure
$0 5/20/93
Failure to operate in a $0
way that minimizes
fire or HW release
Use of defective $0
containers
Failure to label or $0
improperly labeled
containers
Failure to label or $0
improperly labeled
containers
Status Total SEPS Settle Amount Year Issued
Proposed Date Paid Issued By
Penalty
$0 1992 State
$0 1992 State
$0 1992 State
Neg $5,000 $0 1993 State
$0 1993 State
$0 1993 Slate
$0 1993 Stale
$0 1993 State
C-10-16
-------
Summary of RCRA Administrative Orders - Navy (cont.)
Facility
Port Hueneme
WPN Station
WPN Station
WPN Station
Region State Dept
09 CA Navy
02 NJ Navy
02 NJ Navy
02 NJ Navy
Docket #
DO 92/93-
3009
None
None
None
Count Violation
Category
5 Forms, documents,
plans, manuals,
procedures -
inadequate or
incomplete
0
Violation
Description
Contingency plans
1 Unpermitted and Noncompliance with
unauthorized activity permit conditions
2 General O&M
failures
Lack of proper aisle
space in storage areas
Violation Issue
Penalty Date
$0
$0 5/9/94
$1,000
$2,000
Status Total SEPS Settle Amount
Proposed Date Paid
Penalty
$0
Neg $3,000 $0
$0
$0
Year
Issued
1993
1994
1994
1994
Issued
By
State
State
Slate
State
C-10-17
-------
SUMMARY OF RCRA ADMINISTRATIVE ORDERS
USDA
USDA VIOLATION SUMMARY (2nd level)
VIOLATION CATEGORY
44
45
76
72
49
48
43
41
33
TOTAL VIOLATIONS
NUMBER OF VIOLATIONS
5
4
1
1
1
1
1
1
1
16
DESCRIPTION OF VIOLATION
Storage and accumulation issues
General O&M failures
Failure to respond
Security and Safety
Inspections and engineering certification
Nonlisted waste activities
Labeling deficiencies
Unpermitted and unauthorized activity
Training: inadequate/not done
AVG PEN
$18,520
$6,975
$18,750
$2,000
$300
$6,500
$2,000
NA
$300
C-11
-------
Summary of RCRA Administrative Orders - USDA
Facility
Plum Island '-,
Disease- -, . ,
Plum Island
Disease
Plum Island
Disease
Plum Island
Disease
Plum Island
Disease
Plum Island -
Disease
Plum Island
Disease
USDATifton ::
i
USDATiton
USDATifton
USDATiaon
Region State Dept Docket # Count
, 02 '•' - NY USDA-2-KCRA-95- 0
'-' ', •:'.,• - :,: °202 ;'
02 NY USDA 2-RCRA-95- 1
0202
02 NY USDA 2-RCRA-95- 2
0202
02 NY USDA 2-RCRA-95- 3
0202
02 NY USDA 2-RCRA-95- 4
0202
, 02 NY USDA RCRA-95- 0
' ' ;' '-//''' '''•' - '' :, °201 - -', -
02 NY USDA RCRA-95- 1
0201
'. ,04; '='•' ' OA ",'•, USDA, EPD-HW-1097 '0 ,
:,-' - > - " •' , ;
04 GA USDA EPD-HW-1097 1
04 GA USDA EPD-HW-1097 2
04 GA USDA EPD-HW-1097 3
Violation Violation
Category Description
Restricted/Nonlisted Hazardous waste
waste activities stream activities that
do not appear on the
installation permit
Storage and Storage of HW
accumulation issues without interim status
or permit
Unpermitted and TSD of HW without
unauthorized activity permit or interim status
General O&M Incomplete or failure
failures to make HW
determination
Failure to respond Information Request
Storage and Storage beyond
accumulation issues permitted volume
Storage and Storage beyond
accumulation issues permitted time limits
Training: Inadequate training or
inadequate/not done failure to train
environmental staff in
the performance of
their duties as
specified by
Federal/state/local
requirements.
Violation Issue Status Total
Penalty Date Proposed
Penalty
$0 12/27/94 Neg $111,100
$6,500 12/27/94
$79,600 12/27/94
$0 12/27/94
$25,000 12/27/94
$0 10/21/94 Neg $18,750
$18,750 10/21/94
$0 12/22/93 Final $20,500
$2,000
$9,000
$300
SEPS Settle Amount Year
Date Paid Issued
$0 1994
1994
1994
1994
1994
$0 1994
1994
7/12/94 $10,000 1993
$0 1993
$0 1993
$0 1993
Issued
By
EPA
EPA
EPA
EPA
EPA
EPA
EPA
State
State
Slate
State
C-ll-1
-------
Summary of RCRA Administrative Orders - USDA (cont.)
Facility
USDATIfton
USDATifton
USDATIfton
USDATItton
USDATifton
USDATifton
USDATifton
USDATifton
Region State Dept Docket # Count Violation Violation
Category Description
04 OA USDA EPD-HW-1097 4 General O&M Lack of proper aisle
failures space In storage areas
04 GA USDA EPD-HW-1097 5 Storage and Failure to indicate
accumulation issues accumulation or
storage start dates on
containers
04 GA USDA EPD-HW-1097 6 Labeling deficiencies Failure to label or
improperly labeled
containers
04 GA USDA EPD-HW-1097 7 General O&M Use of defective
failures containers
04 GA USDA EPD-HW-1097 8 General O&M Failure to close
failures hazardous waste
(HW) containers
04 GA USDA EPD-HW-1097 9 Inspections and Failure to perform, or
engineering inadequate inspections
certification required in permits or
by Federal/slate/local
regulations.
04 GA USDA EPD-HW-1097 10 Security and Safety Failure to post
hazardous waste
management areas
04 GA USDA EPD-HW-1097 11 Storage and Storage beyond
accumulation issues permitted time limits
Violation Issue
Penalty Date
$300
$1,000
$2.000
$2,000
$600
$300
$2,000
$1,000
Status Total SEPS Settle Amount
Proposed Date Paid
Penalty
$0
$0
$0
$0
$0
$0
$0
$0
Year
Issued
1993
1993
1993
1993
1993
1993
1993
1993
Issued
By
State
State
State
State
State
State
Slate
State
C-ll-2
------- |