Failure to Maintain Waste Shipment Records

The Asbestos NESHAP requires all RACM stripped from a facility’s components to be disposed in accordance with section 61.150. 40 C.F.R. § 61.145(c)(6)(i) (1996). Among other things, section 61.150 requires each owner or operator to maintain waste shipment records for all RACM removed from the facility, including the name and physical site location of the disposal site.

The evidence in the record of this case shows that Friedman & Schmitt did not maintain waste shipment records for the RACM stripped from Building #2. In particular, Mr. Schmitt transported the RACM stripped from Building #2 to his place of business at 2900 Heinz Street. Mr. Schmitt did not prepare a waste shipment record for this transport of RACM from Building #2 to 2900 Heinz Street.

Accordingly, we find that Friedman & Schmitt violated 40 C.F.R. §§ 61.145(c)(6)(i) and 61.150(d)(1) (1996).