EPA Enforcement Roundup: Week of 9/30

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: An aerospace manufacturer
WHERE: Harrisburg, OR
WHAT: RCRA violations
HOW MUCH: $23,136
A company that manufactures custom laminates and thermoplastics for airplanes has been fined by the Oregon Department of Environmental Quality (DEQ) for alleged hazardous waste violations. Although the company is a Federally registered hazardous waste generator, it does not have a permit to treat, store, or dispose of hazardous waste.

DEQ alleges the facility failed to train employees on hazardous waste management, maintain a complete training plan, perform a complete and accurate hazardous waste determination, and properly label and store generated wastes.
 
EPA requires annual training for hazardous waste personnel (40 CFR 262.17). Keep your site in compliance with expert-led RCRA workshops coming to Atlanta, Milwaukee, Detroit, Cleveland, Orlando, Pittsburgh, and more in October 2019.

WHO: A county wastewater facility
WHERE: Pittsburgh, PA
WHAT: Clean Water Act violations
HOW MUCH: $1.2 million, plus $2 billion in initial site improvements
EPA has announced a revision to a 2008 consent decree with a county wastewater facility. Under the original consent decree, EPA alleges the company discharged excessive amounts of sewage into regional waterways. The company was ordered to pay a $1.2 million penalty. Now, the consent decree modification calls for $2 billion in initial site improvements, leaving room for further modifications.

The consent decree modification expands required system improvements to include extensive wastewater treatment plant renovations, as well as over 15 miles of 14-foot diameter tunnels to store and convey wastewater. By 2036, the company is required to have established the first phase of these plans, along with “green infrastructure improvements,” which includes stormwater control measures to store, infiltrate, evaporate, or reuse stormwater and reduce flows to the collection system.
 
WHO: A chemical manufacturing plant
WHERE: Springfield, OR
WHAT: EPCRA violations
HOW MUCH: $60,000 plus a $135,000 Supplemental Environmental Project
EPA has reached a settlement with a specialty chemical facility to satisfy allegations that the company failed to comply with Toxic Release Inventory (TRI) reporting violations under EPCRA. EPA alleges the chemical manufacturer did not report its on-site waste treatment and on-site energy recovery of the toxic chemicals formaldehyde, phenol, and methanol, as well as other violations. 

As part of the settlement, the company has agreed to install additional pollution reduction equipment to reduce plant emissions of formaldehyde, methanol, and phenol. This settlement resolves EPA violations from 2013 to 2017.

Convenient, Effective Online EHS Manager Training

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.

Check out the latest EPA compliance training options here:
 
Clean Air Act Regulations Online
TSCA Regulations Online
Clean Water Act & SDWA Regulations Online
Superfund and Right-to-Know Act Regulations Online (EPCRA & CERCLA)
 
The two-day Complete Environmental Regulations Workshop comes to Orlando on Oct. 23–24. Collaborate with other managers to identify the requirements that apply to your facility and make the big decisons that keep your facility in compliance with EPA's major air, water, and chemical programs. 

See the 2020 schedule here. 

Tags: environmental regulations, EPA, EPA Enforcement Roundup, EPCRA, haz waste, hazardous waste, RCRA, Toxic release inventory, TRI, wastewater treatment