Statewide Compliance Division of the Dept. of Toxic Substances Control is entering into a Consent Order with Romic Environmental Technologies as means of resolving certain violations of the Hazardous Waste Control Law observed during three compliance evaluation inspections. The Consent Order, HWCA Docket No. P2-04/05-004, alleges that Romic Environmental Technology stored hazardous wastes in an unauthorized area, stored hazardous waste in unauthorized containers, and modified an authorized treatment unit without approval from the Department of Toxic Substances Control. The terms and conditions of Consent Order, Docket No. P2-04/05-004 remain in effect until a permit decision is made by the Dept. of Toxic Substances Control on Romic Environmental Technologies' Permit renewal application. The activities authorized in Consent Order, HWCA Docket No. P2-04/05-004 are included in Romic Environmental Technologies' pending premit renewal application. Consent Order, Docket No. P2-04/05-004 authorizes Romic Environmental Technologies to:
1. Handle ignitable and incompatible liquids and solid hazardous wastes in the sampling area: Romic Environmental Technologies is authorized to handle ignitable and incompatible liquid and solid hazardous wastes in other storage and treatment units onsite in its current hazardous waste facility permit;
2. Use of DOT certified vehicles to transfer hazardous waste received from offsite surces in drums to authorized units and to transfer hazardous waste from one authorized unit to another authorized unit; and
3. Legalize modifications made to the Liquefaction Unit, an authorized treatment unit, including:
a. The authorization of the replacement of the 1992 Piping and Instrumentation Diagram (PID) P061, dated January 9, 1992 with the PID dated February 24, 1997 revision 2 (4-2001) and all changes noted therein;
b. The authorization of the replacement of the Solids/Liquids Separation Process Flow Diagram dated June 8, 1989 with the Liquefaction Flow Diagram E-8, dated July 26, 2004 and all changes noted therein;
c. The authorization of the replacement of the 100 gallon blended product tank which had a single shaft mixer with a Cowles Dissolver with PT-1, a 1160 gallon product tank.
d. The authorization of the modernization of the Liquefaction Volatile Organic Compound (VOC) system based on the Shredder and Liquefaction VOC System Modernization Drawing No. E-8b dated February 3, 1999 revision no. 7 (12-03) and all changes noted therein as it pertains exclusively to the Liquefaction Unit; and
e. The replacement of pages in the Romic approved Operation Plan with the documents that reflect the changes made to the Liquefaction Unit described above.
The activities authorized in Consent Docket No. HWCA P2-04/05-004 are minor adjustments to Romic's Part B Permit which will serve to remedy the violations found during the 2001, 2002, and 2003 Compliance Evaluation Inspections and will not have a significant effect on the environment for the following reasons:
1. The activities do not change the types or quantities of hazardous wastes to be processed from those currently permitted to be stored and/or treated at the hazardous waste facility.
2. The activities do not increase the hazardous waste treatment and storage capacity at the hazardous waste facility.
3. The activities do not require any new construction of treatment and/or storage units at the hazardous waste facility.
4. The activities do not provide for any relaxation of standards. The activities shall be conducted in accordance with regulatory standards and in a manner consistent with protocols attached to the Consent Order. The tank certification for Tank PT-1, a 1160 gallon product tank that is part of the modification made to the Liquefaction Unit is part of the Rank Design, Inspection & Certification Services Report #03-02-8 dated and certified February 6, 2003. In addition, the engineering certification of the secondary containment for Tank PT-1 was completed on May 7, 1990 and was included in the previously mentioned certification. The required tank thickness analysis was completed in accordance with American Petroleum Institute Method 650.
5. The Consent Order imposes additional operating standards on Romic Environmental Technologies that exceed regulatory requirements. Within the Sampling Area, the separation of incompatible hazardous waste is accomplished by placement into separate spill containment pallets. Stacking of containers is limited to containers of 5 gallon capacity or less and shall only be stacked on a maximum of two containers high. Inspections of the Sampling Area shall be conducted on a daily basis. Intra-facility transfer vehicles used to transfer hazardous waste from drums to authorized tanks or from one authorized tank to another shall be limited to the exclusive use of DOT certified vehicles. Hazardous waste can remain in transfer vehicles for no longer than 24 hours. Intra-facility transfer vehicles and all associated pipes, hoses, and gauges, while in use, shall be inspected on a daily basis.
6. The activities authorized in the Consent Order are included in the permit renewal package scheduled for release for public comment within the near future.