Document 6wXzgopQZG0z113dgZR7k8o4

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6 1201 ELM STREET, SUITE 500 DALLAS, TEXAS 75270 August 9, 2023 VIA E-MAIL: Aaronlew@lubetech.com Aaron Lewis Lubrication Technologies Inc 7699 W BERT KOUNS IND LOOP Shreveport, LA 71129 RE: Notice of Potential Violation and Opportunity to Confer Dear Mr. Lewis, The United States Environmental Protection Agency, Region 6 ("EPA"), through its investigation and records review, made certain determinations about Lubrication Technologies Inc and its facility located at 7699 W BERT KOUNS IND LOOP, Shreveport, LA. Information currently available to the EPA suggests that Lubrication Technologies Inc may be in violation of/have committed a violation(s) of the Resource Conservation and Recovery Act ("RCRA"), and the regulations promulgated thereunder. By this letter, the EPA is extending to you an opportunity to advise the Agency, in person, via a conference call, or in writing, of any further information the EPA should consider with respect to the potential violation(s). Specifically, EPA has identified potential violations of the Resource Conservation and Recovery Act ("RCRA"), and the regulations promulgated thereunder. I therefore write to share with you: (1) the current areas of concern; (2) an option for resolution; and (3) a timeline for resolution. Current Areas of Concern As a generator of hazardous waste, Lubrication Technologies Inc is subject to Sections 3002 and 3010 of RCRA, 42 U.S.C. 6922 and 6930, and the regulations set forth at Title 33 of the Louisiana Administrative Code (LAC) Part V, Chapters 3-5, 7, and 11 [40 Code of Federal Regulations (C.F.R.) Parts 262 and/or 270]. Upon further investigation, EPA may determine that Lubrication Technologies Inc is also subject to Sections 3004 and 3005 of RCRA, 42 U.S.C. 6924 and 6925, and the regulations promulgated thereunder. Based on EPA's current investigation and records review, Lubrication Technologies Inc is identified as a RCRA Very Small Quantity Generator. However, according to eManifest(s) listed in Attachment 1, at least once within the last five calendar years, the Lubrication Technologies Inc generated hazardous waste in quantities between 100 kilograms and 1,000 kilograms per calendar month, which qualified the Lubrication Technologies Inc as a Small Quantity Generatoras established under Title 33 of the Louisiana Administrative Code (LAC) Part V, Chapters 3-5, 7, and 11 [40 Code of Federal Regulations (C.F.R.) Parts 262 and/or 270]. At a minimum, EPA identified the following potential violations: i. Failure to meet RCRA notification requirements, in violation of RCRA 3010(a), 42 U.S.C. 6930(a); ii. Failure to operate within its stated generator status for at least one (1) year, in violation of LAC: Part V, Chapter 11, 40 C.F.R. Parts 262 and/or 270. EPA is prepared to meet and discuss the potential violations, and other areas of concern, with Lubrication Technologies Inc, with the aim of resolving this matter through a timely settlement process. An Option for Resolution Upon receipt of this letter, if Lubrication Technologies Inc is interested in resolving the matter through settlement, Lubrication Technologies Inc has until 08/21/2023, to inform EPA by telephone or e-mail by contacting: U.S. EPA, Region 6 Enforcement and Compliance Assurance Division (ECDSR) 1201 Elm Street, Suite 500 Dallas, Texas 75270-2102 ATTN: Tripti Thapa e-mail: thapa.tripti@epa.gov Phone: 214-665-7563 Thereafter, Tripti Thapa will make arrangements to discuss this letter with Lubrication Technologies Inc facility representatives via a conference call. During this conference call, Lubrication Technologies Inc may address the potential violations and present evidence that contravenes EPA's evidence. The main goal of this option is to bring the facility into timely compliance with the applicable environmental laws and regulations. To the extent that Lubrication Technologies Inc qualifies as a "small business" under the Small Business Regulatory Enforcement Fairness Act, enclosed is an Information for Small Businesses sheet that provides information on compliance assistance. Timetable for Resolution Given the nature of the potential violations listed above and the current evidence that EPA has in support of these violations, EPA estimates that the parties could have an agreed upon Administrative Order on Consent by 10/09/2023. This is contingent on whether Lubrication Technologies Inc avails itself of the settlement process now offered and works amicably with the EPA. It should be noted that if Lubrication Technologies Inc decides not to accept this streamlined option for settlement, Lubrication Technologies Inc should notify EPA of its decision in writing to Tripti Thapa by 08/21/2023. Thereafter, EPA will exercise its other options for ensuring Lubrication Technologies Inc's timely compliance with RCRA and the regulations promulgated thereunder. Please direct questions to Tripti Thapa of the Waste Enforcement Branch at 214-665-7563 or via email at thapa.tripti@epa.gov. Thank you for your attention to this matter. Sincerely, JEFFREY YURK Digitally signed by JEFFREY YURK Date: 2023.08.09 11:38:38 -05'00' Jeff Yurk Manager Waste Enforcement Branch Enclosure U.S. EPA Small Business Resources Information Sheet eCC: craig.easley@la.gov jimbo.earles@la.gov Manifest Number 020596337JJK 003767948GBF 007037439GBF 006765482GBF 006765470GBF 007037526GBF ATTACHMENT 1 Waste Codes D001, D002, OUTS001H D001 D001 D001 D001 D001 Quantity(KG) 18.955 758.18 834 568.04 417 458.7