Document QkXEMnJw6vOv89o1rz5873Zk7

EPA REGION 2 CARIBBEAN ENVIRONMENTAL PROTECTION DIVISION ENCLOSURE II - RCRA 3008 NOTICE OF VIOLATION Facility Name: Hamilton Sundstrand de Puerto Rico, Inc. EPA ID: PRD987380078 CEPD-RCRA-24-0000-3008-005 On or about January 10, 2024, a duly authorized representative of EPA conducted a Resource Conservation and Recovery Act (RCRA) Hazardous Waste Compliance Evaluation Inspection (CEI) of Hamilton Sundstrand de Puerto Rico, Inc. (the Facility) located at Felicia Industrial Park PR-576 Km 0.7, Santa Isabel, 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. 262.262(a) At the time of the inspection, the Facility failed 40 C.F.R, 262.262(a) which requires a large quantity generator to "submit a copy of the contingency plan and all revisions to all local emergency responders (i.e., police departments, fire departments, hospitals and State and local emergency response teams that may be called upon to provide emergency services). This document may also be submitted to the Local Emergency Planning Committee, as appropriate." The Facility was not able to produce any record that proofs the contingency plan dated January 2022 was submitted to all local emergency responders. The records provided were for an earlier version of the contingency plan dated January 26, 2017. ii. 40 C.F.R. 262.262(b) At the time of the inspection, the Facility failed 262.262(b) which requires a "...large quantity generator that is otherwise amending its contingency plan must at that time submit a quick reference guide of the contingency plan to the local emergency responders...." The quick reference guide that was prepared based on the January 2022 contingency plan was not submitted to local emergency responders. Internet Address (URL) http://www.epa.gov iii. 40 C.F.R. 262.263(d) RCRA 3008 - NOTICE OF VIOLATION Hamilton Sundstrand de Puerto Rico, Inc. EPA ID No. PRD987380078 CEPD-RCRA-24-0000-3008-005 At the time of the inspection, the Facility failed 262.263(d) which requires that "the contingency plan must be reviewed, and immediately amended, if necessary, whenever the list of emergency coordinator changes...." The contingency plan dated January 2022 lists a primary emergency coordinator that has not worked at the Facility since May 2022. There has been no revision of the contingency plan since January 2022. CEPD-RCRA-24-0000-3008-005