1. Establishing and operating a hazardous waste storage facility
    without a permit because of long-term waste storage;
2. Causing the transportation of hazardous waste to a facility
    that did not hold a hazardous waste permit;
3. Failure to evaluate and determine hazardous waste;
4. Failure to provide adequate waste training to facility
    employees;
5. Failure to maintain employee training documentation;
6. Failure to develop and maintain a Contingency Plan;
7. Failure to conduct and document inspections of spill control
    equipment;
8. Failure to maintain adequate aisle space in waste storage
    areas;
9. Failure to mark excess accumulation over 55 gallons with a
    start date;
10. Failure to mark containers with an accumulation start date;
11. Failure to keep containers closed except when  
     adding/removing waste;
12. Failure to conduct and document weekly inspections in
     waste areas;
13. Failure to list all constituents on a land disposal restriction
      form.

The company’s fine: $33,150.
 

Case Study #3


A western Ohio company manufactures basketball backboards as an Indiana corporation doing business in Ohio. It did not have a generator ID number at the time of the inspection. On the day of the inspection, the company told the inspector that it had ceased generating hazardous waste that same day, and that waste currently stored at the company had been generated by prior operations. The inspector detailed the following violations:

1. The company had transported hazardous waste solvent from
    its previous location to an unpermitted facility;
2. Establishing and operating a hazardous waste facility without
    a permit;
3. Failing to evaluate waste stored at the facility.

Although the facility had stored waste for long periods “without a permit”, the OEPA did not enforce an expensive closure process of the waste storage area, as the drums were in good condition, stored inside the facility, and were shipped off-site for disposal. There were no visible signs of a release of waste in the storage area.

The company’s fine: $21,000.


Case Study #4


A northeast Ohio company operated an electroplating facility. It is a large quantity generator of hazardous wastes, including spent plating bath solutions and electroplating wastewater treatment sludges. The company was inspected as a result of a complaint being filed with OEPA claiming mismanagement of wastes. The inspection consisted of the following hazardous waste violations:

1. Storing containers of waste for greater than 90 days without a
    permit in two accumulation areas;
2. Failure to evaluate waste to determine if it was hazardous;
3. Failure to store waste in containers that were closed and in
    good condition;
4. Failure to maintain adequate aisle space;
5. Failure to label and date containers of waste;
6. Failure to conduct inspections or emergency equipment and
    container accumulation areas;
7. Failure to label a satellite accumulation container;
8. Failure to have an emergency communication device and spill
    equipment available at the scene of operations;
9. Failure to describe necessary actions needed to be taken in
   regard to waste generated at the facility; failure to update a
   contingency plan; and failure to list all necessary spill control
   equipment in the plan;
10. Failure to provide annual personnel training documentation’
11. Failure to update job titles and job descriptions for the
     training program;
12. Failure to properly manage universal hazardous waste}
     lamps;
13. Failure to properly label universal waste lamps;
14. Failure to have a system that demonstrates how long
     universal waste lamps have been on-site;
15. Failure to inform employees on the proper handling and
     emergency procedures associated with universal waste 
     lamps;
16. Failure to have a Land Disposal Restriction form for the
     sludge waste.