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EPA Enforcement Roundup: Week of 10/10

Posted on 10/10/2022 by Nick Waldron and Roger Marks

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 used oil transporter & processor
WHERE: Oklahoma City, OK
WHAT: RCRA used oil and hazardous waste violations
HOW MUCH: $1.9 million

The owner of a used oil transportation and processing facility in Oklahoma City has agreed to pay $1.9 million in civil penalties for allegedly violating US EPA’s RCRA regulations for used oil and hazardous waste.

Under RCRA, used oil may be transported and stored according to less-restrictive standards found in 40 CFR Part 279—when specific conditions are met. EPA cited this transporter for failure to perform hazardous waste determinations, storing hazardous waste without a permit, accepting hazardous waste without proper documentation (i.e., the Manifest), and other violations.

In addition to paying the civil penalty, the facility will improve compliance by testing used oil for the presence of hazardous waste, training staff on proper manifest use, developing a written waste management plan, and evaluating their spill prevention and containment procedures.


WHO: A petroleum refinery
WHERE: Redwood City, CA
WHAT: RCRA and Clean Water Act violations 
HOW MUCH: $127,192

For allegedly violating the Clean Water Act (CWA) and RCRA, a Bay Area petroleum refinery has agreed to pay $127,192 in civil penalties.

The refinery is a large quantity hazardous waste generator that receives and processes waste fuel including gasoline, jet fuel, and diesel. This facility is located near two bodies of water that flow into the Pacific Ocean.

The company will also:
  • Develop an air emission monitoring plan.
  • Submit quarterly air emission monitoring results.
  • Inspect and repair tanks to prevent leaks.

The agreement also addresses an alleged violation of the Clean Water Act Oil Pollution Prevention regulations.


WHO: A police department
WHERE: Timonium, MD
WHAT: Hazardous waste violations
HOW MUCH: $15,800

For allegedly failing to properly manage hazardous waste, a county police department has been cited for numerous RCRA violations. The waste generated in this case was lead-contaminated soil from a firing range. Because the soil was contaminated with lead from bullets, it was subject to RCRA standards for management and disposal.

The alleged violations include failure to provide hazardous waste training for employees/staff and failure to have a hazardous waste contingency plan. Because the department did not comply with the conditions for exemption for hazardous waste generators (such as training, recordkeeping, and contingency planning requirements), EPA also issued a citation for “operating a hazardous waste management facility without a permit.”

The enforcement action illustrates how hazardous waste can be generated in unexpected ways, and that failure to identify hazardous waste can lead to preventable violations of the Resource Conservation and Recovery Act (RCRA) regulations.  

EPA Enforcement Roundup: Week of 10/10

Final RCRA Workshops of 2022

Get annually required training for hazardous waste professionals and develop a stronger understanding of the RCRA regulation that apply to your facility.

Lion’s final RCRA Hazardous Waste Management Workshops of 2022 cover the latest Federal hazardous waste management standards—including major updates from US EPA’s Generator Improvements Rule (in effect now in most states). 

St. Louis Oct. 17–18
Atlanta Oct. 24–25
Charlotte Nov. 07–08
Philadelphia Dec. 05–06
Hartford Dec. 12–13


Or check the 2023 workshop and webinar schedules to plan training for next year.

Tags: Clean Water Act, environmental compliance, EPA Enforcement Roundup, hazardous waste management, RCRA

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