Every day, facilities across the US receive Notices of Violation from US EPA for alleged noncompliance with a wide variety of programs like the Clean Air and Clean Water Acts, chemical management and reporting regulations (TSCA, EPCRA, CERCLA, etc.), hazardous waste management and disposal standards (RCRA), and much more.
Below are examples of recent EPA enforcement actions that provide insight into how and why EPA issues civil penalties to facilities for environmental noncompliance. Names of companies and individuals cited by EPA are withheld to protect their privacy.
WHO: A national auto parts retailer
WHERE: 9 CA counties
WHAT: RCRA and Title 22 violations
HOW MUCH: $3.7 million
District Attorneys from nine California Counties filed a joint suit against an auto parts retailer for their alleged illegal hazardous waste disposal operations in the Golden State
. They allege that the company improperly disposed of automotive fluids, batteries, aerosol cans, electronic devices and used oil, and other hazardous substances as well as confidential customer information.
The agreement allows the company to receive a $1.2 million credit if it undertakes an additional $2.4 million enhanced environmental project.
WHO: An oil refinery
WHERE: Prudhoe Bay, AK
WHAT: RCRA violations
HOW MUCH: $125,100
An oil refinery located on Alaska’s North Slope reached an agreement with EPA officials to resolve alleged violations of its Federal hazardous waste permit. According to the agency, the company failed to maintain adequate insurance for bodily injury and/or property damage to third parties that might occur as a result of the company’s storage and handling of hazardous waste.
Their EPA-issued hazardous waste permit requires the company to maintain a dedicated pool of funds of at least $2 million annually,
allowing for $1 million per occurrence in case of third-party injury or losses. Under the permit, the oil refinery is allowed to store over 200,000 lbs. of hazardous waste from oil exploration on leased land in the sensitive tundra environment.
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WHO: A Midwestern municipality
WHERE: Salina, KS
WHAT: Clean Water Act violations
HOW MUCH: $15,188
A city in Kansas has agreed to pay a five-figure settlement for alleged violations of the Clean Water Act. EPA alleges the municipality applied biosolids to land
that contained molybdenum in excess of limits. Federal officials also allege the city failed to perform a Supplemental Environmental Project at a projected cost of $60,000.
Municipal wastewater treatment facilities produce sewage sludge. When that sewage sludge is properly processed and treated, the resulting biosolids are a nutrient-rich organic material that can be used as a fertilizer. In addition, biosolids can be used as daily cover at landfills, stored or used in construction materials.
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Managing site compliance with the many complex EPA programs that affect your business—from the Clean Air and Clean Water Acts to TSCA, EPCRA, CERLCA, and more—is a major challenge. If you’re new to the field, or need an update on changing EPA rules, online training is a convenient way to quickly build in-depth expertise.
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