Search

Chemical Blending Facility Pays $30K for Haz Waste Violations

Posted on 9/7/2021 by Roseanne Bottone

An oilfield chemical blending facility in Sonora, TX faced a $31,404 penalty earlier this year for alleged industrial and hazardous waste violations after inspectors discovered oily discharge on the ground near a chemical storage area.

The Texas Commission on Environmental Quality (TCEQ) cited the company for unauthorized disposal of industrial waste, failure to conduct hazardous waste determinations and classification, failure to keep waste activity records, and for the unauthorized use of saltwater disposal wells.

TCEQ summarizes its enforcement actions in the Texas Register, see pp. 1291–1294

Specific Industrial & Hazardous Waste Violations

Inspectors discovered an oily discharge of approximately 1.33 cubic yard near one of the site’s Solid Chemistry storage areas. The improper discharge to the ground constitutes disposal, in violation of 30 TAC 335.4

The site failed to conduct hazardous waste determinations and waste classification for four waste streams:
  1. Discarded soda ash material,
  2. Spent personal protective equipment,
  3. Oily rags exposed to F003 and F005 listed solvents, and
  4. Wastewaters/liquid waste in the pipe chase associated with oil soluble products.
These deficiencies violated State and Federal requirements for hazardous waste determinations, classification, waste codes, and recordkeeping in 30 TAC Part 335 and 40 CFR 262.11, respectively.

Complete waste activity records for the hazardous and industrial solid waste generated, stored, and disposed of were not available, a violation of the recordkeeping and annual reporting procedures for hazardous waste generators in Texas found in 30 TAC 335.9(a)(1). 

Lastly, the site improperly disposed of 1,190 barrels of liquid waste in saltwater disposal wells not authorized to receive such waste. This violated Texas State rules for waste disposal and permitting in 30 TAC 335.2(b).

Completed Corrective Actions

The company ceased all unauthorized disposal of industrial solid waste at the facility and removed, containerized, and properly managed approximately 101 lbs. of oil-contaminated soil.

In addition, they have complied with the administrative requirements to submit finalized waste stream documentation for the four materials noted above and their corresponding waste activity records.
And finally, they developed and implemented measures designed to ensure that all industrial waste generated at the facility is disposed of at facilities authorized to accept it.

“Good Faith Efforts to Comply”

The TCEQ uses a “Penalty Calculation Worksheet” (PCW) to determine a final penalty. The base penalty can be adjusted according to five line-items:

  • Compliance history,
  • Culpability,
  • Good faith effort to comply,
  • Economic benefit (derived by the facility for not complying), and
  • Other factors as justice may require.

In this case, TCEQ reduced the base penalty by $1,312 because the facility had made a “good faith effort to comply” with the relevant regulations.  

Tags: enforcement, IHW, industrial waste, TCEQ, Texas Hazardous Waste

Find a Post

Compliance Archives

Lion - Quotes

The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again.

John Nekoloff

Environmental Compliance Manager

The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable.

Marc Bugg

Hazardous Waste Professional

The instructor made the class very enjoyable and catered to the needs of our group.

Sarah Baker

Planner

The instructor was energetic and made learning fun compared to dry instructors from other training providers.

Andy D’Amato

International Trade Compliance Manager

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions.

Amanda Oswald

Shipping Professional

The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!

Brian Martinez

Warehouse Operator

Lion was very responsive to my initial questions and the website was user friendly.

Michael Britt

Supply Chain Director

The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

I attended training from another provider and learned absolutely nothing. Lion is much better. Hands down.

Nicole Eby

Environmental Specialist

Download Our Latest Whitepaper

Look beyond the annual "Top 10 List" to see specifics about the most cited OSHA health & safety Standards and the individual regulations that tripped up employers the most last year. 

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.