Poisoning the Air for Eight Years: How Petroleum Management Turned South Baltimore Into a Chemical Dump
The Non-Financial Ledger
Curtis Avenue in South Baltimore is not a zip code that shows up in tourism brochures. It is a working-class stretch of the Patapsco Neck peninsula, hemmed in by industrial facilities on most sides and Curtis Creek on the other. The people who live and work near 5200 and 5218 Curtis Avenue did not choose to live adjacent to a petroleum waste processing plant. Zoning chose that for them. And for at least eight years, from 2014 to early 2022, that plant was venting toxic chemicals into the air they breathed every single day.
Volatile Organic Compounds are not an abstract regulatory category. They are the vapors that rise off petroleum sludge and contaminated wastewater when you leave the containers open to the sky. They include benzene, toluene, ethylbenzene, and xylene, chemicals that are known to cause cancer, damage bone marrow, harm the developing nervous systems of children, and attack the liver and kidneys of adults exposed over time. The EPA’s own mobile air monitoring, conducted in September 2020 at perimeter locations around the facility, detected these compounds drifting off the property. This monitoring happened years into the violation period. The emissions were happening long before anyone with a monitoring device showed up.
What makes this story particularly infuriating is what Petroleum Management was supposed to be doing. This company was in the environmental services business. It was literally paid to safely receive, process, and dispose of petroleum-contaminated hazardous waste from other sites. The legal framework governing their operation was built precisely for this type of facility. The National Emission Standards for Hazardous Air Pollutants, specifically Subpart DD for Off-Site Waste and Recovery Operations, exist because regulators understood that a facility receiving toxic waste from multiple off-site sources could become a concentrated point of toxic air emissions in a community. Every standard Petroleum Management violated was designed to prevent the exact harm Petroleum Management caused.
The VOC-water separator system at the heart of the air pollution violations works like this: when petroleum-contaminated liquid waste arrives at the facility, it runs through a gravity separation system that tries to pull the oil from the water. That process releases vapors. When that system operates with covers and vapor control equipment, the vapors are captured and either combusted or otherwise treated before reaching the air outside. Petroleum Management operated its separators uncovered, or only partially covered, and installed zero vapor control devices. The separated vapors went directly into the neighborhood air. The company was processing over 200 gallons of VOC-laden liquid per day through this system. The true vapor pressure of the material exceeded the regulatory threshold that triggers mandatory vapor controls. Every day it operated this way was a day someone nearby inhaled what the law said should have been captured.
The hazardous waste manifest failure is its own chapter in negligence. On February 6, 2019, the company loaded 6,000 gallons of material onto a truck and sent it to another facility with paperwork calling it “Petroleum Contaminated Water,” a non-hazardous designation. When that material arrived at ERC in Baltimore, ERC’s own testing revealed it was corrosive hazardous waste, EPA Waste Code D002. ERC had to fill out the hazardous waste manifest itself, on behalf of Petroleum Management, before passing the material on to a final disposal facility. There is no way to know how many other shipments were misclassified. There is no way to know what happened to materials that were not caught by a receiving facility sharp enough to re-test the contents. The manifest system exists precisely to track hazardous materials through every step of their journey. The moment that chain breaks, the material is legally invisible.
Then there is the oil spill question. The facility holds up to 80,000 gallons of petroleum products in a system of tanks, strainer boxes, and a solidification pit, all located 2,000 feet from Curtis Creek, which flows into Curtis Bay and the Patapsco River. Federal law requires a Spill, Prevention, Control and Countermeasure plan certified by a licensed professional engineer, updated whenever new tanks are installed, and accurate in its description of what is on site. Petroleum Management installed tanks in 2011 and 2013 without updating its SPCC plan. It amended the plan three times between 2018 and 2021 without having a professional engineer certify those amendments. When inspectors finally reviewed the plan in August 2021, they found it omitted two transfer stations, several connecting pipes, and an oil-water separator. It described inadequate or nonexistent secondary containment for multiple tanks. It incorrectly stated that tanks under 350 gallons did not require secondary containment, which is not what the law says. None of the nine bulk storage tanks on site had ever been tested for structural integrity.
Nine tanks. Holding petroleum waste. Never integrity-tested. Sitting 2,000 feet from a waterway. For years.
The total fine is $230,000. For context, the legal fees associated with negotiating this settlement almost certainly approached a significant fraction of that amount. The fine did not require the company to compensate any individual harmed. It did not require any admission of wrongdoing. The company neither admits nor denies the facts that the EPA spent four years documenting. The people who breathed that air got nothing.
Legal Receipts: What the Documents Actually Say
These are verbatim extracts from EPA Docket No. MM-03-2024-0074. Every word below is from the official Consent Agreement and Final Order, signed and filed on April 12, 2024.
“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.” Consent Agreement, Paragraph 66 — EPA Docket No. MM-03-2024-0074
- The term “major stationary source” is a legal threshold, not a description. Crossing it means a facility is required by law to hold a Title V federal operating permit. Petroleum Management crossed that threshold in 2014 and operated without a permit for eight years.
- “Major source of HAPs” means the facility was emitting hazardous air pollutants at levels requiring specific federal emission standards under Section 112 of the Clean Air Act. Operating without the corresponding National Emission Standards for Hazardous Air Pollutants compliance is a separate and additional violation on top of the missing Title V permit.
“The VOC-water separators were uncovered or partially open to the atmosphere… Respondent had not installed or operated any vapor control devices at the Facility or any other equally effective devices as approved by MDE.” Consent Agreement, Paragraphs 78 and 80 — EPA Docket No. MM-03-2024-0074
- The law (COMAR 26.11.06.06C) requires vapor control when a VOC-water separator receives 200 gallons or more per day of material with a vapor pressure of 1.5 psi or greater. The EPA confirmed both thresholds were met. Zero vapor control devices were present. This is not a technicality; it is the complete absence of required equipment for the entire violation period.
- The phrase “or partially open to the atmosphere” is significant. It means the company made some effort to cover equipment, but left gaps. Those gaps were sufficient to release regulated quantities of toxic vapor into the surrounding community for years.
“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.” Consent Agreement, Paragraph 118 — EPA Docket No. MM-03-2024-0074
- Corrosive material with Waste Code D002 is waste that can destroy tissue, corrode metal, and contaminate groundwater. It requires specific handling, transport, and disposal protocols. Petroleum Management labeled it as ordinary contaminated water, which requires none of those protocols.
- The hazardous waste manifest system is the federal government’s mechanism for tracking toxic materials from origin to final disposal. Petroleum Management broke that chain. The only reason this specific shipment was caught is that the receiving facility tested the material. There is no documented investigation into how many prior shipments were similarly mislabeled.
- The document reveals that ERC, the receiving facility, filed the required manifest on Petroleum Management’s behalf. This means Petroleum Management faced no immediate operational consequence from its own paperwork failure at the time of the violation.
“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.” Consent Agreement, Paragraph 177 — EPA Docket No. MM-03-2024-0074
- Containers 1 through 9 covers every bulk storage tank at the facility. Every single one. The SPCC regulations require integrity testing “on a regular schedule and whenever material repairs are made.” None of the nine tanks holding petroleum waste, located 2,000 feet from Curtis Creek, had ever been tested.
- Integrity testing detects corrosion, wall thinning, and structural weakness before a tank fails. Without it, there is no documented knowledge of whether those tanks were structurally sound. A failure in any one of them could discharge petroleum directly into the drainage system connected to Curtis Creek, Curtis Bay, and the Patapsco River.
“Respondent does not operate air pollution control equipment at the Facility, including vapor combustion equipment capable of destroying or removing HAP.” Consent Agreement, Paragraph 105 — EPA Docket No. MM-03-2024-0074
- This is the operational heart of the air pollution case. A facility receiving off-site hazardous waste with VOHAP concentrations exceeding 500 parts per million by weight must either treat the material to destroy the HAPs, confirm the concentration is below the threshold before accepting it, or operate equipment compliant with NESHAP Subpart DD standards. Petroleum Management did none of these things. It had zero air pollution control equipment of any kind.
- The average VOHAP concentration at the facility’s point of delivery exceeded 500 ppmw, the legal trigger for mandatory controls. The company accepted the material anyway, without controls, and let the vapors escape to the open air.
Societal Impact Mapping
Environmental Degradation
The physical geography around the facility created specific environmental risks that went unmitigated for over eight years.
- The facility’s oil storage capacity of approximately 80,000 gallons sat 2,000 feet from Curtis Creek, a tributary that feeds into Curtis Bay and the Patapsco River. Both Curtis Bay and the Patapsco River are classified as traditional navigable waters of the United States, meaning a spill does not just affect the immediate area; it enters a connected waterway system with ecological and commercial implications.
- None of the nine bulk storage tanks at the facility underwent integrity testing at any point. Federal integrity testing requirements exist specifically to catch corrosion, wall degradation, and structural failure before a tank ruptures. An untested tank holding petroleum waste adjacent to a waterway tributary is an unquantified discharge risk for the entire operational period.
- Several storage units, including the solidification pit, strainer boxes, and Wastewater Receiving Tank 1, were found to be using incompatible containers for oil storage, meaning the materials holding the petroleum waste were not rated or designed for that purpose. Incompatible containers degrade faster and present higher failure risk.
- Secondary containment, the physical barrier system designed to catch spills before they reach the ground and drain systems, was absent or inadequate for Tanks 7, 8, and 9; Wastewater Receiving Tank 1; the solidification pit; drums and totes; and two transfer areas. A spill at any of these points would have moved toward the drainage system without a backup barrier.
- The SPCC plan omitted an oil-water separator from its facility diagram. An oil-water separator is itself filled with petroleum-contaminated material. Its absence from the official spill prevention documentation means it was excluded from spill response planning entirely.
- From 2014 onward, the facility operated as a major source of VOCs and HAPs in Baltimore City, a zone already designated as marginal nonattainment for the 2015 8-hour ozone standard. VOCs are ozone precursors; they react with nitrogen oxides in sunlight to form ground-level ozone. Every ton of VOCs Petroleum Management emitted above the legal limit contributed directly to the ozone load in a city that was already failing to meet federal air quality standards.
Public Health
The combination of VOC emissions and HAP releases from an uncovered, uncontrolled industrial waste operation in a residential-adjacent zone produced documented and foreseeable public health exposure.
- The EPA’s own mobile air monitoring, conducted at perimeter locations adjacent to the facility on September 8, 14, 15, and 16, 2020, detected VOCs and certain hazardous air pollutants. This means the contamination was measurable at the property boundary. People living, working, or spending time near those perimeter locations were breathing air that contained these compounds.
- The VOC-water separator system, left uncovered or only partially covered, processed more than 200 gallons of petroleum-contaminated liquid per day with a true vapor pressure exceeding 1.5 psi. The vapors that evaporate from petroleum waste at that volume include benzene, a known human carcinogen with no safe level of exposure according to EPA classification. Long-term exposure to benzene causes leukemia and other blood cancers.
- The facility received off-site hazardous waste with VOHAP concentrations exceeding 500 parts per million by weight and processed it without any vapor combustion equipment or equivalent HAP-removal technology. The compounds classified as VOHAP under NESHAP Subpart DD include chemicals associated with liver damage, kidney damage, central nervous system damage, and developmental harm in children exposed during critical growth periods.
- Baltimore City’s marginal nonattainment status for ozone means the baseline air quality was already below federal health standards before adding the facility’s emissions. Ground-level ozone causes respiratory inflammation, reduces lung function, aggravates asthma and chronic obstructive pulmonary disease, and increases hospital admissions for respiratory and cardiovascular conditions. Populations already burdened by these conditions faced compounded risk.
- The Facility failed to submit annual emissions statements to the Maryland Department of Environment for at least calendar years 2016 through 2020. This means state regulators were operating without accurate data on how much pollution the facility was actually producing, which impaired their ability to assess cumulative community exposure or enforce air quality standards in the surrounding area.
Economic Inequality
The distribution of industrial pollution risk in Baltimore follows the same lines as economic disadvantage, and the Petroleum Management case illustrates how enforcement timelines and penalty structures fail communities that cannot absorb the cost of corporate non-compliance.
- The facility operated in South Baltimore’s industrial corridor near Curtis Avenue, a geography that historically houses environmental burdens not found in wealthier parts of the city. The communities closest to facilities like this one have less political capital to demand faster enforcement and fewer resources to independently monitor air quality or pursue legal action.
- The violation period ran from 2014 to March 7, 2022. EPA mobile air monitoring began in September 2020. That means at minimum six years passed before the agency conducted field monitoring adjacent to the facility. The gap between when the violations began and when they were detected represents six years of uncompensated community exposure with no regulatory mechanism in place to acknowledge it.
- The $230,000 total penalty translates to approximately $78.77 per day across the eight-year violation period. That figure does not reflect the cost of increased medical care, reduced property values, or lost quality of life for the surrounding community. The settlement contains no victim compensation, no community health fund, and no remediation requirement beyond operational compliance.
- The company neither admits nor denies the specific factual allegations in the Consent Agreement. This standard legal settlement structure prevents the document from being used as an admission in any civil lawsuit a community member might attempt to bring. Affected residents who want to pursue damages must rebuild the evidentiary case from scratch, at their own expense, against a company that can point to a regulatory settlement as evidence the matter is resolved.
- The penalty is not tax-deductible, per the terms of the Consent Agreement. That is a meaningful constraint. But the penalty amount was negotiated down through EPA’s own penalty calculation framework, which accounts for “the economic impact of the penalty on the business” as a mitigating factor. The community’s economic impact from eight years of toxic air exposure is not a factor the same formula accounts for.
The “Cost of a Life” Metric
What Now? Who to Watch and How to Push Back
The settlement is finalized. The penalty has been paid. But the people running Petroleum Management and the regulatory system that took years to respond are still operating. Here is who is accountable and what you can do about it.
Key Parties Identified in Source Documents
- Petroleum Recovery and Remediation Management, Inc. / Petroleum Management, Inc.: 1030 E. Patapsco Ave., Baltimore, MD 21225. Facility at 5200 and 5218 Curtis Avenue, Baltimore, MD 21226. Operations Manager identified in service records: W. Scott Alexander (scott@petromgt.net).
- EPA Region 3 Enforcement Contact: Andrew W. Ingersoll, Assistant Regional Counsel (ingersoll.andrew@epa.gov). Ingersoll signed the Consent Agreement on behalf of the EPA on March 22, 2024.
- EPA Region 3 Enforcement Division Director: Karen Melvin, Director, Enforcement and Compliance Assurance Division, who signed the Consent Agreement on April 11, 2024.
- Maryland Department of Environment (MDE): Received notice of the violations per RCRA Section 3008(a)(2) requirements. MDE administers Maryland’s hazardous waste management program and the state air quality standards central to this case.
Regulatory Watchlist
- U.S. EPA Region 3 (Philadelphia): The agency that investigated and settled this case. Monitor their enforcement database for any follow-up actions, permit applications from this facility, or any future complaints filed. EPA’s Enforcement and Compliance History Online (ECHO) database is publicly searchable.
- Maryland Department of Environment (MDE): The state agency that administers Title V permits, NNSR permits, and annual emissions statements in Maryland. MDE should now have a Title V permit application from this facility on file. Track it. Permits are subject to public comment periods.
- EPA Office of Inspector General: If you believe the settlement amount was inadequate, that enforcement was delayed without justification, or that community health was not adequately weighted, the OIG accepts complaints about EPA enforcement decisions.
- Clean Air Act Citizens Suit Provision (42 U.S.C. § 7604): The Clean Air Act allows private citizens to sue violators directly in federal court when the EPA has not taken adequate action. The settlement resolves EPA’s civil penalty claims, but it does not necessarily bar all citizen enforcement under the citizen suit provision for ongoing violations.
- OSHA Baltimore Area Office: Workers at facilities like this one may face occupational VOC exposure on top of community exposure. OSHA has separate jurisdiction over worker protection that is not addressed in this EPA settlement.
Direct Action and Mutual Aid Steps
- Contact the Maryland Department of Environment’s Air and Radiation Management Administration and request the public record of any Title V permit application filed by Petroleum Management, Inc. after March 7, 2022. That application is a public document and must include the facility’s actual emissions inventory. If no application exists, that is a story worth pursuing.
- Request the EPA ECHO facility compliance report for Petroleum Recovery and Remediation Management (EPA Registry ID searchable by address: 5200 Curtis Ave., Baltimore, MD 21226). Review whether any prior violations appear in the record that predated the 2020 inspection.
- Connect with South Baltimore community organizations and environmental justice groups already working on cumulative industrial pollution in Curtis Bay and the broader Patapsco Neck area. This facility is not the only emission source in that corridor. Cumulative impact assessments require community-level data that no single agency action addresses.
- Submit public comments to EPA Region 3 if and when Petroleum Management’s Title V permit application enters the public notice period. The permit comment process is a legally protected opportunity to force the agency to address community health concerns on the record.
- If you or a family member experienced health impacts near 5200 or 5218 Curtis Avenue during the 2014-2022 period, document those impacts in writing. Keep records. If a class action emerges, that documentation matters. Environmental law organizations including the Chesapeake Legal Alliance and Earthjustice’s Mid-Atlantic office work on industrial pollution cases in the region.
The source document for this investigation is attached below.
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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