Document NeZy08Eo0Mq5rB9D6EKdg12eR

Dated via electronic signature stamp Mr. Brian Hendrickson, Hazardous Waste Media Manager Naval Submarine Base New London RTE 12 Crystal Lake Road Groton, CT 06340 RE: NOTICE OF VIOLATION of the Resource Conservation and Recovery Act of 1976 (RCRA), the Hazardous and Solid Waste Amendments of 1984 (HSWA), 42 U.S.C. 6622(a) and 6924(d) through (m), and CT - Chapter 22a of the Connecticut General Statutes. Dear Mr. Hendrickson: On September 25-26, 2024, representatives of the United States Environmental Protection Agency ("EPA") completed a RCRA compliance evaluation inspection (CEI) of Naval Submarine Baes New London (the "Facility"), EPA ID # CT4170022020. The purpose of this inspection was to determine the compliance of the facility, with CT-RCSA 22a-449(c)-100 through 119, and the federal Hazardous Waste Management Regulations found at 40 CFR Parts 260-273. The State of Connecticut has been granted final authority by EPA to administer certain portions of RCRA. As a result of the inspection noted above, EPA has determined that your facility violated certain provisions of CT-RCSA 22a-449(c)-100 through 119, and the corresponding federal Hazardous Waste Management Regulations found at 40 CFR Parts 260 through 273. The violations are set forth below: 1. Failure to accumulate hazardous waste at or near the specific point of generation and under control of an operator, as required by 22a-449(c)-102(a)(1), which incorporates by reference 40 CFR 262.34(c)(1). Specifically, the following containers were not at or near the point of generation or under the control of the operator at the time of the inspection: One (1) 55-gallon container in building 574 near site S96 had spent mixed rags and bottles placed in it. This site received waste from boat and truck maintenance. One (1) 30-gallon container in building 478 near site S45 was labeled as "Hazardous Waste" with D035 waste code and contained adhesive waste & debris which were being accumulated from the ship/vessel. 2. Failure to make adequate waste determination, as required by 22a-449(c)102(a)(2)(A), which incorporates by reference 40 CFR 262.11. Specifically, the Facility had not conducted a hazardous waste determination on the following waste streams at the time of the inspection: One (1) half-full 30-gallon trash can in building 325 which was accumulating spent rags with unknown substance on them. One (1) 5-gallon bucket at the dock which was across from the Marina (building 535) that was accumulating spent rags. 3. Failure to mark or label each container of used oil with the words, "Used Oil", as required by 22a-449(c)-119(a)(1), which incorporates by reference 40 CFR 279.22(c). ` Specifically, there was one (1) 55-gallon used oil container near site A13 that was not ` marked with the words "used oil" at the time of the inspection. 4. Failure to conspicuously place "No Smoking" sign wherever there is a hazard from ignitable or reactive waste, as required by 22a-449(c)-102(a)(2)(K), which incorporates by reference 40 CFR 265.17(a). Specifically, there was a "No Smoking" sign that was severely faded at building 83 near site A04 and a "No Smoking" sign that had fallen and was on the ground at building 456 near site A19. 5. Failure to amend the contingency plan whenever the list of emergency coordinator changes, as required by 22a-449(c)-102(a)(2)(K), which incorporates by reference 40 CFR 262.34(a)(4), which references 40 CFR 265.54(d). Specifically, the contingency plan was not updated with the current emergency contact. The contingency plan was last updated in 2022 and did not have a designated primary or secondary emergency coordinators. As per Bryan Hernandez, he has been serving as the primary and David Carter as the secondary emergency coordinator. 6. Failure to maintain training records demonstrating annual hazardous waste training requirement, as required by 22a-449(c)-102(a)(2)(K), which incorporates by reference 40 CFR 262.34(a)(4) and 40 CFR 265.16(d)(4). Specifically, David Carter who is a lead environmental protection specialist, Brian Hendrickson who is a hazardous waste media manager, Cory Cavanaugh who is an environmental protection specialist, and Eugenie Kelly who provides hazardous waste 2 trainings to the hazardous waste coordinators throughout the facility did not receive RCRA training in calendar year 2021. The facility must address the requirements set forth above and must immediately begin and continue to operate in compliance with all applicable Federal and State regulations. Within (30) thirty calendar days of receipt of this NOTICE, submit a written description, with supporting documentation (electronic submission preferred), of the actions taken to address requirements number 1 through number 6 above. Submit the information to: Patel.hardik@epa.gov OR Hardik Patel, Environmental Engineer U.S. Environmental Protection Agency Waste and Chemical Compliance Section 5 Post Office Square, Suite 100 [Mailcode: 5-MO] Boston, Massachusetts 02109-3912 Failure to correct the violation as required by this NOTICE may subject the facility to further Federal enforcement action, including the assessment of penalties, pursuant to Section 3008 of RCRA, 42 U.S.C. 6928. Please direct question(s) to Hardik Patel, patel.hardik@epa.gov, phone number 617-918-1163. Thank you for your attention to this matter. Sincerely, O'Donnell, O'Donnell, Mary Jane Digitally signed by Mary Jane 13:42:35 -05'00' Date: 2025.02.03 Mary Jane O'Donnell, Manager Waste and Chemical Compliance Section cc: Joseph Schiavone, CT DEEP 3