EPA Enforcement Roundup: Week of 4/10
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.
Your EPA Enforcement Roundup for this week:
A Connecticut coating and laminating business will pay $305,305 for allegedly violating a Clean Air Act permit.
A manufacturing facility in New Haven, Connecticut reached a settlement with US EPA for allegedly violating the terms of a Clean Air Act permit by emitting volatile organic compounds (VOCs) from coating and laminating operations. EPA alleges that the facility should have destroyed or captured more of the emissions from their activities, instead of releasing them to the air.
The facility uses urethane to coat and laminate fabrics to repel water, chemicals, and/or flames. Their process adds protection to a wide variety of products, including emergency slides for aircraft, protective clothing, and mattresses. The facility has until July 1, 2023, to achieve compliance or permanently shut down coating operations.
Two manufacturers in Iowa face a combined $80,000 in civil penalties for alleged failure to properly manage hazardous waste.
In one RCRA enforcement case, a facility that makes custom hydraulic cylinders allegedly failed to notify EPA that their site generates hazardous waste. Under the RCRA regulations, hazardous waste generators must notify EPA of their activities and obtain a unique EPA ID Number before any hazardous waste is stored, transported, shipped, disposed of, etc. (40 CFR 262.18).
RCRA Re-notification. Large quantity generators (LQG) submit a Biennial Report every two years to keep EPA apprised of their activities. Small quantity generators must re-notify EPA every four years (in states like Iowa where EPA’s Generator improvements Rule is in effect).
Another Iowa manufacturer allegedly failed to make hazardous waste determinations for ignitable and toxic wastes generated on site, failed to properly handle those wastes, and did not have a sufficient RCRA contingency plan in place. Both facilities in Iowa took immediate steps to get back in compliance after the violations were brought to their attention.
In Massachusetts, an aerosol and liquid manufacturing plant agreed to pay $100,000 in restitution for failure to train hazardous waste personnel and other RCRA violations.
An inspection of the company’s hazardous waste management practices uncovered the alleged violations of Federal and State hazardous waste management requirements, including:
- Failure to provide RCRA training for personnel,*
- Failure to inspect containers weekly,
- Recordkeeping and reporting oversights, and
- Insufficient contingency planning/emergency preparedness.
In addition to $43,877 in civil penalties for RCRA violations, the company has agreed spend at least $57,114 to provide the local fire department with two hand held chemical detection units that permit more effective responses to hazardous-waste-related emergencies.
Want a clearer idea of how major EPA air, water, and chemical programs all fit together to affect your site's activities? Join in on the next Complete Environmental Regulations Webinar on May 18–19 at Lion.com.
EH&S professionals who attend can identify the regulations that apply to their facility and locate key requirements to achieve compliance the Clean Air and Clean Water Acts to EPCRA, TSCA, Superfund, and more. Prefer to train at your own pace? Try the interactive online course.
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