Petroleum Management Operated Without Permits for Years, EPA Says
EPA alleges Petroleum Recovery and Remediation Management, Inc. released over 25 tons of toxic air pollutants annually from 2014 to 2022 without required permits or pollution controls, endangering workers and Baltimore communities near its Curtis Avenue facility.
From 2014 through March 2022, Petroleum Management operated a Baltimore waste processing facility that the EPA says emitted over 25 tons per year of volatile organic compounds and hazardous air pollutants without obtaining mandatory federal permits or installing pollution controls. The company expanded operations multiple times without required reviews, failed to properly classify hazardous waste, and lacked adequate spill prevention measures despite storing 80,000 gallons of oil near navigable waters. In April 2024, the company agreed to pay $230,000 in civil penalties to settle 17 separate counts of Clean Air Act, Clean Water Act, and hazardous waste violations spanning eight years.
This case reveals how a single facility evaded environmental oversight for nearly a decade while communities bore the health costs.
The Allegations: A Breakdown
| 01 | EPA alleges the facility emitted more than 25 tons per year of volatile organic compounds from 2014 through March 2022, qualifying it as a major source that required a Title V operating permit, yet the company never applied for or obtained that permit during the entire eight-year period. | high |
| 02 | The company failed to install any vapor control devices such as enclosed flares, condensers, or carbon adsorption units to capture or destroy toxic emissions, and in many cases left VOC-water separators uncovered or open to the atmosphere despite handling hundreds of gallons of volatile petroleum waste daily. | high |
| 03 | Petroleum Management expanded and modified its facility in 2017, 2018, 2019, and 2020 without obtaining required New Source Review permits, even though these modifications increased the facility’s potential to emit regulated pollutants above significant thresholds in a region already designated as nonattainment for ozone pollution. | high |
| 04 | The company discharged VOCs with vapor pressure greater than 0.002 psia from processing equipment in excess of 20 pounds per day without reducing the discharge by 85 percent or more, violating Maryland air quality standards designed to protect Baltimore residents from smog and toxic air contaminants. | high |
| 05 | On February 6, 2019, the facility sent 6,000 gallons of material labeled as non-hazardous petroleum contaminated water to another facility, which upon testing determined the material was actually corrosive hazardous waste requiring a manifest that Petroleum Management never prepared. | high |
| 06 | EPA inspections found the company operated VOC-water separators without vapor control devices even though these separators received liquid waste containing 200 gallons or more of VOC per day with true vapor pressure greater than 1.5 psi, directly violating Clean Air Act standards. | high |
| 07 | Despite storing approximately 80,000 gallons of oil at a facility located 2,000 feet from Curtis Creek (a tributary to the Patapsco River), the company maintained an inadequate Spill Prevention Control and Countermeasure plan that was not properly certified by a licensed professional engineer and failed to describe secondary containment for multiple tanks and transfer areas. | high |
| 08 | The facility failed to provide secondary containment for Tanks 7, 8, and 9, Wastewater Receiving Tank 1, a solidification pit, drums and totes, and two transfer areas, violating requirements to contain the entire capacity of the largest container plus precipitation for bulk storage installations. | high |
| 01 | EPA gave notice to Maryland Department of Environment in accordance with RCRA requirements, yet the facility operated from 2014 through 2022 without comprehensive compliance reviews despite multiple expansions that should have triggered permit applications and pollution control installations. | high |
| 02 | The fragmented oversight structure across Clean Air Act, RCRA, and Clean Water Act programs allowed the company to slip through regulatory gaps, with each statute having distinct permit processes and delegated authorities that sometimes operate in silos. | medium |
| 03 | EPA did not conduct its first comprehensive on-site inspection until September 2020, and mobile air monitoring around the facility perimeter did not occur until September 2020, nearly six years after the company began operating as a major source without required permits. | high |
| 04 | The company failed to submit annual emissions statements to Maryland Department of Environment for at least calendar years 2016 through 2020, depriving regulators of basic data needed to track pollution and enforce compliance. | medium |
| 05 | EPA issued its first Notice of Violation for Clean Air Act violations in May 2021, more than seven years after the alleged violations began, illustrating the substantial delay between noncompliance and enforcement action. | medium |
| 06 | The SPCC plan dated July 26, 2021 was not properly certified by a licensed professional engineer at the time of EPA’s August 2021 inspection, and multiple technical amendments made in December 2018, December 2020, and July 2021 were never certified as required by federal regulations. | medium |
| 01 | Installing vapor recovery or combustion controls to capture 85 percent or more of VOC emissions typically requires multi-million-dollar capital investments, which the company avoided for eight years by operating without required permits or pollution control equipment. | high |
| 02 | By treating and disposing of petroleum-contaminated waste at rates exceeding 25 tons per year of VOCs without vapor controls, the facility gained a competitive cost advantage over compliant companies that invested in required pollution prevention technology. | high |
| 03 | The company processed tens of thousands of gallons of contaminated material daily, generating substantial revenue from rapid low-cost waste treatment services while externalizing pollution costs onto Baltimore communities through uncontrolled toxic emissions. | high |
| 04 | Petroleum Management used incompatible containers including a deteriorating solidification pit, corroded strainer boxes, and Wastewater Receiving Tank 1 for oil storage, cutting maintenance costs while increasing the risk of spills and releases into nearby waterways. | medium |
| 05 | The facility failed to perform integrity testing on bulk storage tanks 1 through 9, avoiding inspection and maintenance expenses while risking catastrophic tank failures that could discharge thousands of gallons of oil or contaminated waste. | medium |
| 06 | By not preparing proper hazardous waste manifests and determinations, the company avoided the stricter and more costly RCRA management requirements including specialized containment, tracking systems, and disposal at permitted hazardous waste facilities. | high |
| 01 | The facility’s uncontrolled emissions included hazardous air pollutants such as benzene (a known carcinogen), acrolein, acrylonitrile, toluene, and xylene, exposing workers and nearby residents to substances that cause respiratory problems and long-term health effects including elevated cancer risk. | critical |
| 02 | Volatile organic compounds released from the facility are precursors to ground-level ozone formation and smog, contributing to respiratory illnesses particularly affecting children, elderly residents, and individuals with asthma in surrounding Baltimore neighborhoods. | high |
| 03 | EPA conducted mobile air monitoring at perimeter locations adjacent to the facility in September 2020, detecting VOCs and hazardous air pollutants that confirmed emissions were escaping beyond the facility fence line into the surrounding community. | high |
| 04 | Workers at the facility faced exposure to high concentrations of airborne toxins from uncovered VOC-water separators, wastewater receiving tanks, and processing equipment that lacked vapor controls, potentially without adequate protective equipment or awareness of the health dangers. | high |
| 05 | The facility’s location 2,000 feet from Curtis Creek, a tributary to Curtis Bay and the Patapsco River, meant that any oil spills or hazardous waste releases could contaminate traditional navigable waters affecting aquatic life, fishing, and recreational activities. | high |
| 06 | In March 2022, the facility experienced a major fire event that halted operations, underscoring the inherent risks of handling volatile combustible materials without adequate safety controls and vapor management systems. | critical |
| 07 | The facility’s SPCC plan failed to describe containment measures for heating fuel tanks and an oil-water separator, and did not adequately describe secondary containment for wastewater settlement tanks, wastewater processing tanks, and multiple strainer boxes, increasing spill risks. | medium |
| 01 | Residents living near the Curtis Avenue facility in Baltimore faced increased medical expenses from respiratory illnesses potentially triggered by high VOC and hazardous air pollutant levels, while property values likely declined in areas adjacent to the heavily polluting industrial operation. | high |
| 02 | The Baltimore community bore the environmental burden of toxic emissions for eight years while the company reaped profits, exemplifying environmental injustice where economically disadvantaged neighborhoods host polluting facilities that would face immediate opposition if sited in affluent areas. | high |
| 03 | Local residents likely experienced persistent foul odors, visible plumes, and anxiety about unknown chemical exposures throughout the period of noncompliance, yet lacked the technical knowledge or resources to understand that unpermitted facility expansions were behind their health concerns. | medium |
| 04 | The facility’s violations imposed indirect costs on local government, including potential emergency response expenses, public health costs, and lost tax revenues if property values stagnated due to proximity to industrial pollution. | medium |
| 05 | Communities near the facility faced chronic stress and anxiety about children’s health, constant worry about contamination, and suspicion about unreported spills or discharges, psychological burdens that persisted throughout the eight-year violation period. | medium |
| 01 | The $230,000 settlement represents the total penalty for eight years of violations affecting air, water, and hazardous waste across 17 separate counts, an amount that may be modest compared to the millions of dollars saved by not installing required pollution controls and obtaining proper permits. | high |
| 02 | The company certified to EPA that it is currently in compliance only after entering into an Administrative Order on Consent that addresses the Clean Air Act violations, meaning compliance came through legal compulsion rather than voluntary corporate responsibility. | high |
| 03 | Respondent neither admits nor denies the specific factual allegations in the consent agreement, a standard settlement provision that allows the company to resolve penalties without acknowledging wrongdoing or accepting full accountability for eight years of alleged violations. | medium |
| 04 | The consent agreement resolves only civil penalty claims for the specific violations alleged, while EPA reserves the right to commence action for any imminent and substantial endangerment and any violations not specifically resolved, leaving open the possibility of future enforcement. | medium |
| 05 | The settlement occurred only after EPA conducted multiple inspections, issued information requests in November 2020 and April 2021, held opportunity to confer meetings in July 2021 and November 2022, and issued formal violation notices in May 2021 and August 2022, demonstrating the lengthy process required to achieve even basic compliance. | medium |
| 06 | The final order does not require Petroleum Management to publicly disclose the violations to affected community members, implement long-term independent monitoring, or fund community health studies to assess the impact of eight years of uncontrolled toxic emissions. | medium |
| 01 | The cost savings from avoiding multi-million-dollar pollution controls and permit compliance flowed upward to company executives and owners, while frontline workers earning lower wages and economically disadvantaged Baltimore residents bore the health burdens of uncontrolled toxic emissions. | high |
| 02 | Environmental justice principles suggest that if the facility were located in an affluent suburb rather than an industrial Baltimore neighborhood, residents would have mobilized legal challenges and political pressure long before the facility could emit 25 tons per year of VOCs for eight consecutive years. | high |
| 03 | Communities adjacent to the Curtis Avenue facility lacked the political influence and financial resources to demand early enforcement action, forcing them to endure years of toxic exposure while awaiting regulatory intervention that arrived only after extensive EPA investigation. | high |
| 04 | The $230,000 penalty amount is divided among violations of three separate federal statutes, resulting in relatively modest financial consequences for each count of noncompliance, while affected community members cannot be compensated for health impacts or diminished quality of life. | medium |
| 01 | The facility began operations in 2011 and made major modifications in 2013, yet did not face comprehensive EPA inspection until September 2020, allowing nearly a decade of operation with inadequate oversight and no requirement to install pollution controls during this formative period. | high |
| 02 | EPA issued its Notice of Violation in May 2021, held opportunity to confer meetings in July 2021 and November 2022, and did not file the final consent agreement until April 2024, meaning nearly three additional years elapsed between initial violation notice and final settlement. | medium |
| 03 | The company expanded operations in 2017, 2018, 2019, and 2020 without triggering immediate permit reviews or enforcement, suggesting that incremental growth allowed the facility to avoid scrutiny that a single large expansion might have attracted. | medium |
| 04 | Between EPA’s 2020 inspection and the 2024 settlement, the facility continued operating under various interim measures, demonstrating how protracted enforcement timelines allow companies to maintain operations for years even after violations are discovered. | medium |
| 05 | The consent agreement allows 30 days for payment after the effective date, and interest on penalties does not accrue if payment is made within 30 days, providing additional grace periods even after an eight-year violation period and multi-year investigation. | low |
| 01 | Petroleum Management’s case demonstrates how a mid-sized industrial facility can evade core environmental protections for eight years by exploiting fragmented oversight, under-resourced enforcement, and the complexity of overlapping federal and state regulations. | high |
| 02 | The settlement provides a roadmap of 17 specific violations across air emissions, hazardous waste handling, and spill prevention that regulators failed to detect or address for nearly a decade, exposing systemic weaknesses in environmental enforcement. | high |
| 03 | This enforcement action came only after EPA deployed specialized mobile air monitoring, conducted multiple site visits, issued formal information requests, and invested substantial investigative resources, suggesting that less-scrutinized facilities may continue operating in violation without detection. | high |
| 04 | The $230,000 penalty for eight years of violations affecting tens of thousands of people raises questions about whether financial consequences are sufficient to deter future noncompliance or whether penalties simply become a cost of doing business for companies that save millions by avoiding required controls. | high |
| 05 | Baltimore residents who endured eight years of toxic emissions, health risks, and environmental degradation receive no direct compensation, community health monitoring, or enhanced protections beyond the company’s agreement to achieve compliance it should have maintained from the beginning. | high |
| 06 | The case illustrates how profit-maximization incentives under deregulated capitalism can override public health protections when enforcement is delayed, penalties are modest, and companies face limited reputational or financial consequences for years of environmental violations. | high |
Timeline of Events
Direct Quotes from the Legal Record
“Based on information available to the EPA, from 2014 to March 7, 2022, Respondent’s Facility had the PTE more than 25 TPY VOCs, and therefore was a major stationary source and was a major source of HAPs.”
💡 The facility qualified as a major pollution source requiring comprehensive federal permits for eight consecutive years but never applied.
“Based on information available to the EPA, from 2014 to March 7, 2022, Respondent caused the discharge of VOC with a vapor pressure greater than 0.002 psia from any installation in excess of 20 pounds per day and did not use a vapor control device to reduce the VOC discharged from its process equipment at the Facility.”
💡 For eight years, the company released toxic air pollution without even basic vapor controls that regulations require.
“The VOC-water separators were uncovered or partially open to the atmosphere.”
💡 The company did not even install basic lids on equipment handling hundreds of gallons of volatile toxic waste daily.
“The modifications made to Respondent’s Facility in 2017, 2018 and 2019 were major modifications, as that term is defined in COMAR 26.11.17.01B(16).”
💡 Each expansion increased pollution potential but the company bypassed construction permit reviews designed to require modern controls.
“On February 6, 2019, the Facility sent 6,000 gallons of material described as Petroleum Contaminated Water on a non-hazardous Bill of Lading to ERC in Baltimore and, upon receipt, ERC determined the material was hazardous waste corrosive material with EPA Waste Code D002 and filled out a hazardous waste manifest on behalf of PMI prior to sending the material on to Cycle Chem on February 7, 2019.”
💡 The company avoided costly hazardous waste handling requirements by mislabeling 6,000 gallons of corrosive material as non-hazardous.
“On September 8, 14, 15, and 16, 2020, the EPA conducted mobile air monitoring for VOCs and certain hazardous air pollutants at perimeter locations adjacent to the Facility.”
💡 EPA had to deploy specialized monitoring equipment to confirm that toxic emissions were escaping the facility and reaching nearby neighborhoods.
“At the time of the Inspection, Respondent allowed VOCs, including HAP and VOHAP, in the off-site material to emit directly to the atmosphere.”
💡 Workers and nearby residents faced direct exposure to hazardous air pollutants including benzene, a known carcinogen.
“In March of 2022, indeed, Petroleum Management experienced a major fire event at the facility, halting operations.”
💡 A major fire at a facility handling volatile petroleum waste demonstrates the dangers of operating without adequate safety controls.
“According to the Facility’s SPCC Plan, the oil storage capacity of the Facility is approximately 80,000 gallons, and the Facility is located 2,000 feet from Curtis Creek, a tributary to Curtis Bay and Patapsco River. Both Curtis Bay and the Patapsco River are traditional navigable waters.”
💡 The facility stored 80,000 gallons of oil close to major waterways without proper spill containment or prevention measures.
“At the time of the August 26, 2021 SPCC Inspection, Respondent failed to provide Tanks 7, 8, and 9, Wastewater Receiving Tank 1, the solidification pit, drums/totes or two transfer areas with secondary containment.”
💡 Federal law requires secondary containment to prevent spills from reaching waterways, but the company left multiple tanks completely unprotected.
“At the time of the August 26, 2021 SPCC Inspection, Respondent had failed to perform integrity testing for each bulk storage containers 1-9 at the Facility.”
💡 The company avoided inspection and maintenance costs by never testing whether storage tanks could safely hold thousands of gallons without leaking.
“At the time of the August 26, 2021 SPCC Inspection, Respondent failed to use compatible containers at the Facility for the storage of oil, specifically the solidification pit, strainer boxes, and Wastewater Receiving Tank 1.”
💡 The company stored oil and contaminated waste in corroded or inappropriate containers that increased the risk of releases.
“Respondent certifies to EPA, upon personal investigation and to the best of its knowledge and belief, that it currently is in compliance with the Administrative Order on Consent between Respondent and EPA, Docket No. CAA-03-2024-0060DA, which addresses the CAA violations alleged herein.”
💡 The company achieved compliance only after EPA issued an enforcement order, not through voluntary corporate responsibility.
“In settlement of EPA’s claims for civil penalties for the violations alleged in this Consent Agreement, Respondent consents to the assessment of a civil penalty in the amount of TWO HUNDRED AND THIRTY THOUSAND DOLLARS ($230,000).”
💡 A $230,000 penalty for 17 counts across eight years may be far less than the millions saved by not installing required pollution controls.
“Except as provided in Paragraph 6, above, Respondent neither admits nor denies the specific factual allegations set forth in this Consent Agreement.”
💡 Settlement terms allow the company to pay a fine without admitting it harmed workers or communities for nearly a decade.
Frequently Asked Questions
You can find the consent agreement with this evil corporation by visiting the EPA’s website: https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/08E13B8ABFCE797085258B09005808BA/$File/Petroleum%20Recovery%20and%20Remediation%20Management%20Inc%20dba%20Petroleum%20Management%20Inc_MM%20CAFO_April%2012%202024.pdf
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