EPA Enforcement Roundup: Week of 7/18

Posted on 7/17/2017 by Roger Marks

Every day, facilities across the US receive Notices of Violation from Federal and State environmental agencies 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.
In January 2017, EPA raised its fines for noncompliance with major environmental programs. We hope that providing information about EPA enforcement cases will help you identify and fix noncompliance issues that could leave your company facing costly penalties and future liability.

In this week’s EPA Enforcement Roundup, a high-tech manufacturer and a pharmaceuticals maker will pay for RCRA hazardous waste violations, and plastic “nurdles” cause a Clean Water Act headache for two plastics companies.  

WHO: 2 plastics manufacturers
WHERE: Sun Valley and Pacoima, CA
WHAT: Clean Water Act violations
HOW MUCH: $67,900 combined

color-pellets-2.jpgAfter finding 1/5-inch plastic pellets, or “nurdles,” in storm drains headed for the Los Angeles River, EPA has resolved Clean Water Act allegations with two California plastics manufacturers. “Nurdles” are tiny pellets used in the plastic manufacturing process. They are also a major polluter of waterways, according to EPA.   

This isn’t the first time “nurdles” have made an appearance in the EPA Enforcement Roundup. In December 2016, a Valencia, CA manufacturer spent over $300,000 to resolve stormwater permitting violations after allegedly discharging nurdles to a local waterway.

WHO: A high-tech manufacturer and R&D firm
WHERE: Jessup, MD
WHAT: RCRA hazardous waste violations
HOW MUCH: $76,200

To settle alleged violations of EPA’s RCRA hazardous waste requirements, a Jessup, Maryland manufacturer will pay a $28,200 civil penalty and donate nearly $50,000 in equipment to local emergency responders. According to EPA’s press release, the company failed to meet its hazardous waste management compliance responsibilities—including failure to:
  • Provide RCRA hazardous waste training for personnel as required at 40 CFR 262;
  • Identify hazardous waste subject to regulation under RCRA; 
  • Properly label and manage containers of hazardous waste; 
  • Correctly use a Manifest for hazardous waste off-site shipments;
  • Maintain an adequate hazardous waste contingency plan
As part of the settlement, the Howard County, MD Fire Department hazardous materials response team will receive $46,900 in emergency response equipment, including new communications tools.

WHO: A pharmaceuticals manufacturer
WHERE: Salisbury, MD
WHAT: RCRA hazardous waste violations
HOW MUCH: $35,000

For allegedly failing to properly manage lab solvents and corrosive cleaners under the RCRA hazardous waste requirements, a pharmaceuticals manufacturer will pay a $35,000 civil penalty.

According to US EPA, the company stored hazardous waste in excess of the 90-day accumulation limit for large quantity generators. In addition, the facility failed to properly label or manage containers of hazardous waste, failed to maintain an adequate hazardous waste contingency plan, and did not submit a timely and complete biennial report. 

The RCRA rules for managing hazardous waste changed dramatically this year. From new labeling and contingency plan rules to a wholesale re-organization of RCRA, these big updates will impact your site in major ways. Be confident you know what to expect when your state adopts EPA’s Generator Improvements Rule! Find initial or refresher RCRA training in the classroom nationwide or online 24/7 at

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ENV-300-computer-image.jpgManaging 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, the Complete Environmental Regulations Online Course will help you quickly build in-depth expertise.

Or, check out the latest individual EPA compliance training options here:
Clean Air Act Regulations Online
TSCA Regulations Online
New! Clean Water Act & SDWA Regulations Online
Just Launched! Superfund and Right-to-Know Act Regulations Online 
The 2017 nationwide schedule for the Complete Environmental Regulations Workshop is now available. Collaborate with other managers to identify the requirements that apply to your facility, ask the right questions, and make the right decisions about EPA compliance.

Tags: Act, Clean, EPA, EPA Enforcement Roundup, fines and penalties, hazardous waste, RCRA, Water

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