Document jg5zpv79vwoBv1OGa78LxpKn9

Dated via electronic signature stamp URGENT MATTER - EARLY WARNING NOTICE CERTIFIED MAIL - RETURN RECEIPT REQUESTED Mr. Daniel Sweet Senior Environmental, Health & Safety Manager Vicor Corporation 400 Federal Street Andover, MA 01810 Re: NOTICE OF POTENTIAL VIOLATION of the Resource Conservation and Recovery Act (RCRA), the Hazardous and Solid Waste Amendments of 1984 (HSWA) and Massachusetts, General Law, Chapter 21C, Sections 4 and 6. The State of Massachusetts has been granted final authorization by EPA to administer certain portions of RCRA. Dear Mr. Sweet: On October 07 through 08, 2024, representatives of the United States Environmental Protection Agency ("EPA") conducted a RCRA compliance evaluation inspection. The purpose of this inspection was, in part, to determine the compliance of Vicor Corporation, EPA ID # MA5000000570, with the relevant hazardous waste management regulations for the State of Massachusetts and corresponding federal Hazardous Waste Management Regulations found at 40 C.F.R. Parts 260-273. As a follow up to the detailed out-brief provided by EPA at the conclusion of the compliance evaluation inspection of your facility, a partial written list of deficiencies is provided below to summarize the potential violations/areas of concern identified. Additional potential violations or areas of concern determined subsequent to EPA's inspection may also be included in the list below. You are requested to take immediate action on your part to evaluate this listing below and take corrective measures where necessary. Potential Violations/Areas of Concern: 1. Failure to obtain a license for the storage of hazardous waste for greater than 90 days. 2. Failure to review and immediately amend the contingency plan and to distribute a copy to the local emergency response agencies. 3. Failure to equip the hazardous waste accumulation area with water at adequate volume and pressure to supply water streams or foam. Daniel Sweet Vicor Corporation Page 2 4. Failure to ensure a container of hazardous waste remains closed during storage, except when waste is being added or removed. 5. Failure to provide a program of instruction or on-the-job training that teaches personnel assigned to the management of hazardous waste to perform their duties. 6. Failure to remove/clean spilled or leaked hazardous waste in timely manner. 7. Failure to make adequate waste determinations. 8. Failure to inspect areas where hazardous waste containers are stored, at least weekly. 9. Failure to equip the hazardous waste accumulation area with a device, such as a telephone. 10. Failure to post an up-to-date written list near telephones at the site of hazardous waste accumulation containing information regarding emergency coordination/equipment/procedures. 11. Failure to maintain aisle space between the hazardous waste containers at the hazardous waste accumulation site. 12. Failure to mark and/or label each container of hazardous waste with the words, "Hazardous Waste", the hazardous waste identified in words, and the type of hazard(s) associated with the waste(s) indicated in words. 13. Failure to meet the satellite accumulation area hazardous waste container accumulation requirement. 14. Failure to meet the dating requirement for the universal waste. This letter is EPA's initial response to potential hazardous waste violations and areas of concern that were observed during October 07-08, 2024, inspection of your facility. The primary purpose of this letter is to identify potential problem areas and seek compliance. This Notice does not limit or otherwise preclude EPA from taking civil or criminal enforcement action pursuant to Section 3008 of RCRA, 42 U.S.C. 6928 with regard to these or other violations that may be determined. EPA is continuing to investigate and evaluate Vicor Corporation's compliance under RCRA and may take an enforcement action as appropriate. I urge you to take immediate positive steps to remedy the above-cited potential violations/areas of concern. If you have any questions regarding this letter or how to comply with RCRA requirements, please contact Hardik Patel of my staff at (617) 918-1163. Sincerely, O'Donnell, O'Donnell, Mary Jane Digitally signed by Mary Jane 13:52:22 -05'00' Date: 2024.12.12 _________________________ Mary Jane O'Donnell, Manager Waste and Chemical Compliance Section cc: Scott Fasulo, MassDEP, NERO