Document BywXqgOX4YVe99LyJ1nY3QEvJ

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6 1445 ROSS AVENUE, SUITE 1200 DA LLAS. TX 75202-2733 05/ 16/2018 CERTIFIED MAIL-RETURN RECEIPT REQUESTED: 7014015000002406 1212 Randal G Andras Prime Coatings Inc. PO Box 1223 Arrielia, LA 70340 RE: Potential RCRA Violations and Opportunity for Settlement Dear Mr. Andras, The United States Environmental Protection Agency, Region 6 ("EPA"), through its investigation and records review, made certain dete1minations about Prime Coatings Inc. and its facility located at PO Box 1223, Amelia, LA. 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 cunent areas of concern; (2) an option for resolution; and (3) a timeline for resolution. Current Areas of Concern As a generator of hazardous waste, Prime Coatings Inc. is subject to Sections 3002 and 3010 ofRCRA, 42 U.S.C. 6922 and 6930, and the regulations set forth at Title 33 ofthe 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 Prime Coatings 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 cunent investigation and records review, Prime Coatings Inc. identified as a RCRA conditionally exempt small quantity generator status. However, at least once within the last five calendar years, the facility generated hazardous waste in quantities between 100 kilograms and 1,000 kilograms per calendar month, which qualified the facility as a small quantity generator as established under Title 33 of the Louisiana Administrative Code (LAC) Pmt V, Chapters 3-5, 7, and 11 [40 Code of Federal Regulations (C.P.R.) Palis 262 and/or 270].