FISCAL YEAR: 2003

The facility historically operated an electroplating line, and received an Administrative Order from TNRCC to properly clean up the abandoned line. TNRCC was verifying completion of the cleanup and found that the cleanup had not been initiated. Incompatible plating wastes were stored in close proximity of each other. That verification inspection also led to the discovery of various wastes assocated with pyrotechnic and incendiary devices. RTF Industries has apparently made pyrotechnic devices under various contracts. Bulk materials included highly reactive white phosphorus, magnesium flakes and organic peroxides. Water reactive chemicals were stored in a building which the roof was seriously compromised due to the historical operation of the plating operation. The State reported that a large magnesium flake container was noted to be standing in water on the floor and water was seen on the top of the container, despite clear label warnings that the material reacts violently with water. Other containers were leaking unknown contents. The RTF Industries owner is a chemical engineer formerly and he maintained that the materials were products, and therefore not subject to environmental waste regulations. While some materials were legitimate products, exceptionally poor industrial hygiene was apparent in storage and care of the chemicals. Much of the material was classified as waste based upon the discarded/abandoned standard of care.

June 18, 2003

STATUTE:

• Resource Conservation and Recovery Act (RCRA)