EPA Enforcement Roundup: Week of 11/14

US businesses are subject to complex, overlapping environmental regulations related to air emissions, discharges to water, hazardous waste management and disposal, oil spills, chemical management, and more. Failure to comply with all applicable US EPA requirements can result in future liability and civil penalties as high as $100,000+ per day, per violation.

The EPA enforcement actions highlighted below provide insight into how and why the Agency assesses civil penalties for environmental noncompliance.

All violations mentioned are alleged unless we indicate otherwise. We withhold the names of organizations and individuals subject to enforcement to protect their privacy.

WHO: A pharmaceutical manufacturer
WHERE: Rancho Cordova, CA
WHAT: RCRA hazardous waste violations
HOW MUCH: $69,879

A facility that manufactures pharmaceutical ingredients faces about $70,000 in civil penalties for allegedly failing to comply with RCRA requirements for managing hazardous waste.

Violations alleged by US EPA include failure to properly label hazardous waste containers, failure to separate incompatible wastes during accumulation, and failure to adequately address emergency equipment in the site contingency plan.  

In addition, EPA alleges that the facility did not comply with requirements for monitoring and testing equipment for leaks, and did not have a qualified engineer assess the integrity of a tank.

WHO: A used oil recycler
WHERE: Oklahoma City, OK
WHAT: RCRA used oil violations
HOW MUCH: $1.9 million

For allegedly violating multiple provisions of the Resource Conservation and Recovery Act (RCRA) used oil and hazardous waste regulations, a used oil transporter and a used oil processing facility will pay $1.9 million in civil penalties.

According to authorities, the two companies (which are under the same ownership) failed to make hazardous waste determinations for used oil on site. The companies also allegedly stored hazardous waste without a permit and accepted hazardous waste for transportation without the required Manifest.

Lastly, EPA alleges failure to comply with standards for transportation, storage, and recordkeeping related to used oil. The companies have already undertaken some required measures to achieve compliance—which include training staff on proper use of the Manifest, developing a written waste management plan, and updating emergency preparations.

WHO: Oil and gas production wells
WHERE: 3 Ohio counties
WHAT: Clean Air Act violations
HOW MUCH: $2.9 million (penalties + injunctive relief)

For alleged Clean Air Act violations, including failure to control air emissions from oil and wastewater storage vessels, a company operating oil and gas production wells in Ohio will pay a $1 million civil penalty and complete $1.9 million in injunctive relief at fifteen facilities.

In addition to emissions violations, the company allegedly failed to inspect storage vessels for leaks and meet some recordkeeping and reporting responsibilities. EPA inspections noted uncontrolled emissions of volatile organic compounds (VOCs) from storage vessels. Pressurized gases were venting through seals on hatches, pressure relief devices, and combustors.  

EPA estimates that, once complete, the required equipment upgrades will significantly reduce emissions of VOCs, methane, and carbon dioxide.

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Tags: Clean Air Act, EPA Enforcement Roundup, hazardous waste management, RCRA