dec 20, 1996 - MDEQ Violation - Letter of Warning

Description:

Gary Sayers
Electro-Plating Service, Inc.
959 E. 10 Mile

John Engler, Governor
Department of Environmental Quality
HOLLISTER BUILDING.
PO BOX 30473, LANSING Ml 48909-7573
INTERNET: http://www.deq.s:ate.mi.us
RUSSELL J. HARDING, Director

December 20, 1996

Madison Heights, Michigan 48071
Dear l'vfr. Sayers:
SlJBJECT: l'v1ID042444687, Hazardous Waste Inspection--Fully Regulated Status

FILE
REPLY TO
CADILLAC DISTRICT
120 CHAPIN ST W
CADILLAC Ml 49501

On November 4, 1996, staff of the Michigan Department of Environmental Quality (.MDEQ) conducted an inspection of Electro-Plating Service, Inc., located at 959 E. 10 Mile, Madison Heig.1-its, Michigan, to evaluate compliance of that facility with the Part 111: Hazardous Waste Management, of the Natural
Resources and Environmental Protection Act, 1994 PA 451, as amended, MCL 324.11101 et seq (Part I 1 I);
Subtitle C of the Federal Resource Conservation and Recovery Act (RCR.A.), as amended; Part 121: Liquid
Industrial Wastes, of the Natillal Resources and Environmental Protection Act, 1994 PA 451, MCL
324.12101�(Pan121); and ;my regulations promulgated pursuant to these Acts. A copy of the
completed inspection form can be obtained by contacting this office .
• .6..s a result of the inspection, s-..aff of the MDEQ have determined that the above facility is in violation of the
following:
1. Facility shall maintain a copy of the test results, waste analysis or other determinations for waste
evaluation on-site for thr� years from t'1e date that the waste was last sent off-site. (Rule 307(1):
40 CFR. 262. 40(c)) No an2lysis was available for the waste oil.
2. Restricted hazardous waste which exceeded established treatment standards or prohibitions shall have
a notice accompanying each shipment of the waste off-site. (Rule 306(1Xd): 40 CFR 268.7(a)(l)) One
shipment of TCE on May 17, 1996, MI297169 does not have a notice of land disposal restriction.
3. 1 The notice must include: (Rule 306(1)(d): 40 CFR 268.7(a)(l)(i-v) or 268.7(a)(2)(i)(A-D) or
268.7(a)(3)(i-iv) ) \Vhethe:-the waste is wastewater or non-wastewater as defined in 268.2(d&f)., and
each waste code associated with the shipment. MI 1527478, lacks this information.
4. A complete biennial report shall be submitted to the U.S. EPA by March 31. (Rule 308(1 ):
40 CFR 262.41) Please com.actUSEPA at (312) 886-7439 to obtain a report.
5. The date upon which each period of accumulation began must be marked a.'1d visible for inspection on
each container. (Rule 306(1)(b): 40 CFR 262.34(a)(2)) While being accumulated on-site each
container of hazardous wse must have the words "Hazardous Waste" marked or clearly labeled on it.
(Rule 306(l)(c): 40 CFR 262.34(a)(3)) While being accumulated on-site each container of hazardous

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December 19, 1996
Page Two

waste must have the haza:dous waste number marked or clearly labeled on it. (Rule 306(l)(b)) The
three drums of1CE in storage were not appropriately labelled.
6. A facility may accumulate hazardous waste on-site for less than 90 days, from the date upon which the
period of accumuiarion began, wirhout having a permit or without having interim status. (Rule.306( 1 ))
Tne last shipment of TCE was on May 17, 1994, and this implies storage of more than 90 days.
7. A container(s) holding hazardous waste must always be closed except when adding or removing waste.
(Rule 306( l)(a): 40 CFR::65.173(a)) Containers of hazardous waste were stored open.
8. Weekly container and container area inspections for leaks and deterioration must be documented.
(Rule 306(1 )(a)(i)) I left a form which can be used to document these inspections.
9. Employee training documentation was unavailable Rule 306(l)(d): 40 CFR 265.16(d)(I)) I left a
handout that may assist you in gaining compliance.
10. The contingency plan mll:>"1 contain the following information:
a) Actions personnel will take to respond to fires, explosions, or unplanned release of hazardous
waste. (Rule 306(l)(d): 40 CFR 265.52(a&b))
Electro-Plating Service,)nc., must respond to the violations noted in this letter . Please submit
documentation to this office regarding those actions taken to address the violations by March 1, 1996. Tne
NIDEQ will evaluate the respor.se and determine compliance status and notify you of this determination.
This Lener of Warning does not preclude nor limit the :MDEQ's ability to initiate any other enforcement
action, under state. or federal law, as deemed appropriate.
Attached, for your information., is a handout explaining the Pollution Incident Prevention Plan required for
certain facilities under Part 31; Water Resources Protection, of the Natural Resources and Environmental
Protection Act, 1994 PA 451, MCL 324.3101. A short informational sheet on waste minimization; an
infonnation sheet on recycling fiuorescent lamps; and information on PCB bailasts.
If you have any questions, plezse feel free to contact me.

Enclosures

Sincerelv,

j
) _- / ;k 'i2u<(fr.-t---
1 U"1, l.9- .
CJi;ri G. McLaughlin j

' ·
E�vironrnentat Quality Analyst
Waste Management Division
616-775-3960 e>..1. 6201

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