EPA Says ITU Absorb Tech Failed Basic Hazardous-Waste Controls

The Facts

ITU Absorb Tech operates a commercial laundry at 818 West Spring Street in Titusville. It cleans uniforms, gloves, floor mats, mops, towels, reusable absorbents and chemically contaminated cloths known as shop rags for other facilities and organizations.

The shop-rag process generated a concentrated solvent waste stream. Solvent recovery dryers removed material containing toluene and xylene before the rags entered ordinary washing and drying. EPA said the recovered waste contained more than 10% organic material by weight and traveled through containers, pipes, pumps and valves before reaching a 6,000-gallon storage tank.

The facility reported itself to the Pennsylvania Department of Environmental Protection as a large quantity generator of hazardous waste. It didn’t have a hazardous-waste treatment, storage or disposal permit. That isn’t automatically a violation: federal rules allow a large quantity generator to accumulate waste without a permit if it meets specified operating conditions. EPA concluded that ITU Absorb Tech failed several of those conditions and therefore lacked a valid permit exemption.

How the Solvent System Worked

The equipment rules in this case weren’t detached paperwork requirements. They followed the physical path of the solvent through the laundry. EPA regulations required the company to determine which equipment contacted sufficiently concentrated organic hazardous waste, identify that equipment and monitor relevant pumps and valves for leaks.

What EPA Documented

EPA representatives inspected the Titusville facility on May 21, 2024. The resulting agreement describes failures ranging from an unlabeled 20-gallon solvent container to the absence of a leak detection and repair program.

What the Control Failures Meant

The tank-inspection rule requires operators to look for corrosion, releases, wet spots, dead vegetation and problems in secondary containment at least once each operating day. EPA’s account means the company lacked records demonstrating that those checks occurred on approximately 390 days. Most were weekends and holidays.

Missing records aren’t proof that the tank leaked. They do remove the documented assurance that its condition and surrounding containment were checked as required. The same distinction applies to the absent monthly monitoring program: the agreement establishes that pumps and valves weren’t being monitored under the applicable leak rules, not that EPA detected a leak from them.

The personnel finding was also narrower than a conclusion that workers had received no training. EPA said the written job descriptions failed to state hazardous-waste duties, qualifications and training requirements. The agreement doesn’t establish whether the employees holding those jobs were otherwise trained.

For the fluorescent lamps, EPA documented poor storage and tracking practices but reported no broken lamps, release or exposure. The available record likewise identifies no injury, contamination measurement, cleanup cost or documented effect on Titusville residents.

The evidence establishes missing safeguards and missing documentation. It does not establish that an unmonitored release reached workers, neighbors or the environment.

From Inspection to Final Order

What the Final Order Actually Decided

The final order ratified the consent agreement and ordered ITU Absorb Tech to comply with its terms. The company accepted a $101,000 civil penalty payable within 30 days of the effective date, waived its right to contest the allegations and waived an appeal.

That procedural outcome matters. ITU Absorb Tech didn’t admit the specific factual allegations, and EPA didn’t decide them after a contested hearing. The company did certify, after what the agreement calls a personal investigation and to the best of its knowledge and belief, that the facility was currently compliant with respect to the alleged violations.

What a Legitimate Fix Looks Like

ITU Absorb Tech’s compliance certification says the cited deficiencies have been corrected. Keeping them corrected requires controls that can be verified rather than reconstructed after the next inspection:

• Document every required operating-day tank inspection, including qualifying weekends and holidays, with the condition of the tank and secondary containment recorded.
• Maintain an equipment inventory or piping diagram identifying every pump, valve, flange and connector that contacts the regulated solvent waste stream.
• Run and preserve records from the required monthly leak detection and repair program.
• Make hazardous-waste duties, qualifications and training requirements explicit in the records for every relevant position.
• Keep discarded lamps in closed, structurally sound, correctly labeled containers with a traceable accumulation date.

Those measures correspond directly to the failure modes EPA identified. They would also give future inspectors something the 2024 inspection repeatedly lacked: a contemporaneous record showing that the controls operated when required.

What Remains Unresolved

The agreement doesn’t provide emissions measurements, leak-monitoring results, sampling data or evidence of a tank release. It doesn’t identify an exposed worker, an affected resident or environmental contamination. Nor does it describe the individual corrective steps behind the company’s compliance certification.

The final order therefore fixes the legal consequence—a binding settlement and $101,000 penalty—without answering whether any hazardous material escaped during the years when EPA says required monitoring and inspection controls were missing. That boundary between documented control failures and an undocumented environmental outcome is the limit of the available record.