“During the RCRA inspection, the inspector observed three hazardous waste storage containers that the Facility had failed to properly label with the words, ‘Hazardous Waste.'”

💡 This concealed the dangerous nature of the contents from workers and emergency responders who might encounter these containers.

“During the RCRA inspection, the inspector observed three hazardous waste storage containers that the Facility had failed to provide labeling indicating the hazards of their contents.”

💡 Without knowing whether materials are ignitable, corrosive, reactive, or toxic, personnel cannot take appropriate safety precautions.

“During the RCRA inspection, the inspector observed a full 55-gallon container of waste paint related material in the paint operations area that the Facility had failed to label with an accumulation start date. The Facility had filled this container approximately two weeks prior to the RCRA inspection.”

💡 Accumulation dates track how long hazardous waste remains on site and help prevent containers from deteriorating beyond safe storage limits.

“According to the RCRA inspection report, the inspector documented that the Facility was a small quantity generator, and that the Facility failed to obtain an EPA identification number from the Administrator prior to the four offsite shipments of hazardous waste.”

💡 Federal law requires this identification number before any hazardous waste can legally leave the facility, ensuring proper tracking and accountability.

“During the RCRA inspection, the inspector documented that the Facility used bills of lading for four offsite hazardous waste shipments and therefore failed to prepare the required Manifests for these four offsite shipments of hazardous waste.”

💡 Manifests create a paper trail tracking where toxic waste ends up, while bills of lading eliminate accountability for final disposal.

“During the RCRA inspection, the inspector identified two used oil containers that the Facility had failed to label or mark with the words ‘Used Oil.'”

💡 Unmarked containers conceal their contents from workers and first responders, creating exposure risks during handling or emergencies.

“After considering these factors, EPA has determined, and Respondent agrees that settlement of this matter for a civil penalty of twelve thousand five hundred dollars ($12,500.00) is in the public interest.”

💡 This penalty amount for six categories of violations suggests that the financial consequences of noncompliance are minimal compared to compliance costs.

“In signing this Agreement, Respondent: (a) admits that Respondent is subject to RCRA and its implementing regulations; (b) admits that EPA has jurisdiction over Respondent and Respondent’s conduct as alleged herein, (c) neither admits nor denies the factual allegations contained herein; (d) consents to the assessment of this penalty.”

💡 The company resolved the case without acknowledging it violated federal environmental laws, preserving its public reputation.

“By its signature below Respondent certifies, subject to civil and criminal penalties for making a false submission to the United States Government, that: (a) the alleged violations have been corrected, and (b) it is presently in compliance with all requirements of RCRA, 42 U.S.C. § 6901 et. seq., its implementing regulations, and any permit issued pursuant to RCRA.”

💡 The company certified its own corrective actions without independent verification or ongoing monitoring requirements in the settlement.

“Full payment of the civil penalty shall only resolve Respondent’s liability for federal civil penalties for the violations alleged herein. The EPA reserves the right to take any enforcement action with respect to any other past, present, or future violations of RCRA or any other applicable law.”

💡 The settlement covers only these specific violations, suggesting EPA anticipates the need for continued oversight of this facility.

“By signing this Agreement, Respondent waives any rights or defenses that Respondent has or may have for this matter to be resolved in federal court, including, but not limited to any right to a jury trial, and waives any right to challenge the lawfulness of the final order accompanying the Expedited Settlement Agreement.”

💡 The expedited settlement process eliminated the company’s ability to contest the violations in court or before a jury.

“The penalty specified herein shall represent civil penalties assessed by EPA and shall not be deductible for purposes of Federal, State and local taxes.”

💡 This provision ensures taxpayers do not subsidize the cost of environmental violations through corporate tax deductions.

“40 C.F.R. § 262.18(a) requires that a generator must not treat, store, dispose of, transport, or offer for transportation, hazardous waste without having received an EPA identification number from the Administrator.”

💡 This fundamental requirement forms the foundation of federal hazardous waste tracking, yet CPM Waterloo made four shipments without it.

“40 C.F.R. § 262.20(a) requires a generator that transports or offers for transport a hazardous waste for offsite treatment, storage, or disposal, or a treatment, storage, or disposal facility that offers for transport a rejected hazardous waste load, to prepare a Manifest.”

💡 Manifests track hazardous waste from generation to final disposal, but CPM Waterloo substituted bills of lading that provide no such accountability.

“The EPA has provided the State of Iowa with notice of the referenced violations of Subtitle C of RCRA as required by Section 3008(a)(2).”

💡 Federal law requires state notification of hazardous waste violations, but the settlement occurred at the federal level without additional state-level remediation requirements.