1. Pursuant to 40 CFR 262.11, a person who generates a solid waste must determine if that waste is hazardous. This facility did not make hazardous waste determinations on eight wastes.

2. Pursuant to IC 13-30-2-1(1), no person shall discharge, emit, cause, or allow any contaminant or waste, including any noxious odor, either alone or in combination with contaminants from other sources, into the environment in violation of

40 CFR 265.31. This facility allowed material to be released to the floor and around equipment in three separate areas.

3. Pursuant to 40 CFR 262.34(a)(4) referencing 40 CFR 265.31, facilities must be maintained and operated to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste to the air, soil, or surface water, which could threaten human health or the environment. This facility failed to properly manage its facility to minimize a release to the environment.

4. Pursuant to IC 13-30-2-1(10) and 40 CFR 270.1(c), no person shall commence or engage in the operation of a hazardous waste facility without having first obtained a permit from IDEM. This facility operated as a hazardous waste storage facility without having first obtained a permit.

5. Pursuant to 329 IAC 3.1-1-10, every hazardous waste generator, transporter, or owner or operator of a hazardous waste facility, must notify the Commissioner of its hazardous waste activity on the approved forms. This facility failed to notify the Commissioner of hazardous waste storage activities.

6. Pursuant to 40 CFR 262.34(b), a generator who accumulates hazardous waste for more than 90 days is an operator of a storage facility and is subject to the requirements of 40 CFR Part 264 and the permit requirements of 40 CFR Part 270. This facility stored hazardous waste on-site for greater than 90 days without complying with 40 CFR 264 and 40 CFR 270.

7. Pursuant to 40 CFR 261.4(c), a hazardous waste which is generated in a product or raw material storage tank, or in a manufacturing unit, is not subject to regulation until it exits the unit in which it was generated, or unless the hazardous waste remains in the unit more than 90 days after the unit ceases to be operated for manufacturing, or for storage or transportation of product or raw materials. This facility left material in two process units for greater than 90 days after the units ceased to be operated and failed to manage the waste as a hazardous waste.

8. Pursuant to 40 CFR 261.1(b)(8), a material is "accumulated speculatively" if it is accumulated before being recycled. A material is not accumulated speculatively, however, if the person accumulating it can show that the material is potentially recycled and has a feasible means of being recycled; and that - during the calendar year (commencing on January 1) - the amount of material that is recycled, or transferred to a different site for recycling, equals at least 75 percent by weight or volume of the amount of that material accumulated at the beginning of the period. This facility speculatively accumulated cubic yard boxes of lead dross.

9. Pursuant to 40 CFR 262.34(a)(1)(i) referencing 40 CFR 265.171, if a container holding hazardous waste is not in good condition, or if it begins to leak, the generator must transfer the hazardous waste from this container to a container that is in good condition. This facility stored hazardous waste in containers that were not in good condition.

10. Pursuant to 329 IAC 13-4-3(d), generators must label all used oil containers and aboveground tanks with the words "Used Oil." This facility did not label several used oil containers with the words "Used Oil."

11. Pursuant to 40 CFR 262.34(a)(4) referencing 40 CFR 265.52(f), a facility's contingency plan must include an evacuation plan. This facility's contingency plan did not include an evacuation plan.

12. Pursuant to 40 CFR 262.34(a)(4) referencing 40 CFR 265.54, a facility’s contingency plan must be amended whenever applicable regulations are revised; the plan fails in an emergency; the facility changes its design, construction, or operation; or the list of emergency coordinators or emergency equipment changes. This facility failed to amend the contingency plan to reflect changes in operations at the plant.