Document ybrNQyLYpqRLbydK5xYva8k3D
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6 1445 ROSS AVENUE, SUITE 1200
DALLAS, TX 75202-2733
January 11, 2016
CERTIFIED MAIL-RETURN RECEIPT REQUESTED: 7015 1520 0003 3990 2164
Ben Buchhanan Environmental Manager Memorial Hermann Southwest Hospital 7600 Beechnut Street Houston, TX 77074
RE: Potential RCRA Violations and Opportunity for Settlement
Dear Mr. Buchanan,
The United States Environmental Protection Agency, Region 6 ("EPA"), through its investigation and records review, has made certain preliminary determinations about Memorial Hermann Southwest Hospital, located at 7600 Beechnut Street, Houston, Texas 77074 ("Memorial Hermann"). Specifically, EPA has identified potential violations ofthe 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, Memorial Hermann is subject to Sections 3002 and 3010 ofRCRA, 42 U.S.C. 6922 and 6930, and the regulations set forth in 30 TEX. ADMIN. CODE Subchapters_C and/or F, which implement regulations found in 40 C.F.R. Parts 262 and/or 270. Upon further investigation, EPA may determine that Memorial Hermann is also subject to Sections 3004 and 3005 ofRCRA, 42 U.S.C. 6924 and 6925, and the regulations promulgated thereunder.
Based on EPA's current investigation and records review, Memorial Hermann has been generating hazardous waste and offering its hazardous waste for transportation and/or directly for