Document 0gyN7pe4VnKdXg61wd4xbQ8m

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2 CARRIBEAN ENVIRONMENTAL PROTECTION DIVISION CITY VIEW PLAZA II BUILDING, 7TH FLOOR ROUTE 165 GUAYNABO, PUERTO RICO 00968 ENCLOSURE II - RCRA 3008 NOTICE OF VIOLATION Boehringer Ingelheim Animal Health Puerto Rico LLC EPA ID: PRR000025189 CEPD-RCRA-23-0000-3008-010 On or about July 19, 2023, a duly authorized representative of EPA conducted a Resource Conservation and Recovery Act (RCRA) Hazardous Waste Compliance Evaluation Inspection (CEI) of the Boehringer Ingelheim Animal Health Puerto Rico LLC (the Facility) located at Rd 2 Km 56.7 Bo Trinidad, Barceloneta, Puerto Rico, pursuant to Section 3007 of RCRA, 42 U.S.C. 6927. As a result of the CEI, EPA has identified the following violations of the RCRA regulations. i. 40 C.F.R. 262.15(a)(5)(i) At the time of the inspection, Boehringer Ingelheim Animal Health Puerto Rico LLC failed 40 C.F.R, 262.15(a)(5)(i) which required a generator to mark or label its container with the following: "the words "Hazardous Waste...". The Facility failed to comply with this requirement in the F6 Satellite Accumulation Area (SAA) and in the Paint Shop SAA. At the F6 SAA, a 5-gallon container of isopropyl alcohol waste was not marked and/or labeled with the words "hazardous waste" and at the Paint Shop SAA, a 55-gallon drum of waste paint was not marked and/or labeled with the words "hazardous waste". ii. 40 C.F.R. 262.15(a)(5)(ii) At the time of the inspection, Boehringer Ingelheim Animal Health Puerto Rico LLC failed 40 C.F.R, 262.15(a)(5)(ii) which required a generator to mark or label its container with the following: "An indication of the hazards of the contents (examples include, but are not limited to, the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic); hazard communication consistent with the Department of Transportation requirements at 49 CFR part 172 subpart E (labeling) or subpart F (placarding); a hazard statement or pictogram consistent with the Occupational Safety and Health Administration Hazard Communication Standard at 29 CFR 1910.1200; or a chemical hazard label consistent with the National Fire Protection Association code 704)." Internet Address (URL) http://www.epa.gov RCRA 3008 - NOTICE OF VIOLATION Boehringer Ingelheim Animal Health Puerto Rico LLC EPA ID No. PRR000025189 CEPD-RCRA-23-0000-3008-010 The Facility failed to comply with this requirement in the F6 SAA and in the Paint Shop SAA. At the F6 SAA, a 5-gallon container of isopropyl alcohol waste was not marked and/or labeled with an indication of the hazards of the contents and at the Paint Shop SAA, a 55-gallon drum of waste paint was not marked and/or labeled with an indication of the hazards of the contents. CEPD-RCRA-23-0432