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The United States Environmental Protection Agency (“EPA”) and RAM Aircraft, L.C. (“RAM”) entered into a July 22nd Consent Agreement and Final Order (“CAFO”) addressing alleged violation of the Resource Conservation and Recovery Act (“RCRA”) regulations. See Docket No. RCRA-06-2020-0982.
The CAFO provides that RAM operates a facility (“Facility”) in Waco, Texas, engaging in aviation engine overall and aviation support.
EPA is stated to have conducted a RCRA record review of the Facility’s activity as a generator of hazardous waste from March through August 2020. Based on this review, EPA is stated to have determined that RAM generated hazardous waste streams in quantities that exceeded the threshold amount of 100 kilograms of non-acute hazardous waste in a month, corresponding to Small Quantity Generator (“SQG”) and 1,000 kilograms of non-acute hazardous waste in a month, corresponding to Large Quantity Generator (“LQG”) status under 40 C.F.R. Part 262 for the periods that such wastes remained onsite.
Alleged violations identified in the CAFO include:
- Failure to file with EPA or Texas an adequate and timely notification of hazardous waste activities during 2015 through 2019
- Failure to operate within its stated RCRA generator status
RAM neither admits nor denies the specific factual allegations contained in the CAFO.
The CAFO requires that RAM take the following actions within 90 calendar days of the effective date of the CAFO:
- Certify assessment of all solid waste streams at the Facility to determine accurate waste codes and develop and implement standard operating procedures to ensure that it is operating the Facility in compliance with RCRA and the regulations promulgated thereunder, including but not limited, procedures for:
- Making hazardous waste determinations.
- Managing hazardous wastes.
- Reporting, transporting, and disposing of hazardous waste.
- Preparing manifests.
- Meeting requirements of land disposal requirements
- Certify that the Facility accurately and adequately with its RCRA Section 3010 notification for the Facility and within the prescribed time period
- Provide, with its certification, a copy of the Facility’s standard operating procedures as previously described
A civil penalty of $55,064 is assessed.
A copy of the CAFO can be downloaded here.
