EPA Enforcement Roundup: Week of 9/12

Posted on 9/12/2022 by Roseanne Bottone and Nick Waldron

US businesses are subject to complex, overlapping environmental regulations concerning 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 (and growing every year).

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 warehousing and storage facility
WHERE: Odenton, Maryland
WHAT: RCRA hazardous waste violations
HOW MUCH: $54,900

A warehouse used to store personal care products allegedly violated the RCRA hazardous waste regulations by failing to maintain an adequate contingency plan, perform regular inspections, train hazardous waste personnel, and keep records of hazardous waste training.

Because the warehouse did not comply with the “conditions for exemption” for generators, they are also alleged to have operated a hazardous waste treatment, storage, or disposal facility without a permit. Facilities that fail to comply with the RCRA requirements for large, small, or very small quantity generators can be penalized for operating a non-exempt facility.

WHO: A chemical storage and distribution center
WHERE: Brookfield, CT
WHAT: Clean Air Act and EPCRA violations
HOW MUCH: $179,596

For allegedly failing to “design and maintain a safe facility” and neglecting to submit reports required under EPCRA, a company that repackages, formulates, and stores hazardous chemicals will pay a civil penalty and come into compliance with US EPA requirements.

The Clean Air Act General Duty Clause (Section 112(r)(1)), requires covered stationary sources to maintain a safe facility, take steps to prevent releases, and minimize the consequences of releases that occur.  EPCRA requires facilities that manufacture, process, or use large volumes of chemicals to submit annual Toxics Release Inventory (TRI) reporting for substances listed in 40 CFR 372.65. The facility used and stored listed chemicals including chloroform, formaldehyde, and sulfuric acid.

Read more: What’s New for TRI Reports in 2022?

EPA Enforcement Roundup: Week of 9/12

WHO: A metal valve and pipe fitting manufacturer
WHERE: Pageland, South Carolina
WHAT: RCRA hazardous waste violations
HOW MUCH: $87,000

For alleged violations related to the site contingency plan, personnel training, and universal waste management, a metal valve and pipe fitting manufacturer faces an $87,000 civil penalty.

The site’s quick reference guide, now required as part of the contingency plan in states that have adopted EPA’s Generator Improvements Rule, was missing required elements. The site map did not indicate the areas where hazardous wastes are generated or routes for accessing the wastes, for instance.

In addition, inspectors found that employees did not receive required hazardous waste training in 2019—2020 and that the site’s records did not name employees in positions that require training. Lastly, open and unlabeled boxes of universal waste fluorescent lamps were observed in the facility’s maintenance shop.

2022 RCRA Training Workshops

Join Lion for in-person RCRA training to help satisfy US EPA’s initial or annual refresher requirement for hazardous waste personnel before the year ends.

RCRA Hazardous Waste Management Workshop

Chicago Oct. 3–4
StLouis Oct. 17–18
Atlanta Oct. 24–25
Charlotte Nov. 7–8
Philadelphia      Dec. 5–6
Hartford Dec. 12–13

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Tags: CERCLA settlement, environmental compliance, hazardous waste management, RCRA contingency plan, RCRA violations

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