What $153,174 Cannot Account For

Picture a factory floor. Rubber belts rolling off machines, conveyor systems, dryer belts destined for someone’s laundry room. It looks like industry. It looks like work. What the EPA inspectors found on January 14 and 15 of 2025, behind the production floor, inside the lab, inside the storage rooms, told a different story.

In the laboratory, there were containers of hazardous chemical waste stacked in a corner, gathering dust. One of those stacks had a spill visible inside it. The spill had dried out and solidified. It had been there long enough to harden in place, and nobody had moved it, cleaned it, or even labeled it as hazardous. Some of the containers in that laboratory were laying on their sides. Not all of them were fully closed.

Fifteen containers of a hazardous solvent-based substance called “dough” sat under a fume hood in that same lab. They had no date written on them. They had no label saying “Hazardous Waste.” They had been estimated, by the inspectors themselves, to have been sitting there for approximately two and a half years. The legal limit is 90 days.

In the room called the OSS room, there was a 55-gallon drum labeled simply “Tar,” dated May 11, 2024, nearly eight months before the inspection. There was a gallon container someone had hand-labeled “Old Waste Thinner,” dated January 6, 2024, over a year before inspectors arrived. Neither container was properly labeled as hazardous waste. Both had been sitting there, in a room that regulators say went entirely uninspected for the entirety of 2022.

The rubber cement itself, the actual substance this plant uses to manufacture its products, had coated the walls, the equipment, the floor, and the floor grating of an area called the Long V Cement House. That coating is classified D001: ignitable hazardous waste. It was not in a container. It was on the surfaces people worked near every day.

The people who worked in these spaces did not make this mess by accident and walk away. They worked in it, around it, and through it, every shift. Workers whose job titles are connected to hazardous waste management had not completed their required annual safety training reviews. The company had not maintained written job descriptions for hazardous waste roles. Nobody had documented what training those workers were supposed to receive, or whether they received it.

When you strip away the regulatory language, what happened here is this: a major industrial company operating in a residential-adjacent city decided, through action or through indifference, that its legal obligations around toxic material handling were optional. Workers were not equipped with the documentation, training oversight, or inspected environment the law requires. The community surrounding 4021 N 56th Street in Lincoln, Nebraska, had no idea any of this was happening inside that building. They still might not.

“A spill that had solidified in place.” That is not an oversight. That is a timeline. Someone saw it happen and nobody acted until the federal government showed up.

Straight From The Document: What The EPA Actually Found

The following are direct quotes from the Consent Agreement and Final Order, Docket No. RCRA-07-2026-0006, filed with the EPA Region 7 Hearing Clerk on December 23, 2025. These are not allegations by an advocacy group. These are the government’s own words, which ContiTech signed and did not contest.

“Various waste chemicals and materials containers (D001, D002, D035, F005, U002, U154, U220, and U239) stacked in a pile, gathering dust, with at least one visible spill inside the pile that solidified in place, in the south corner of the laboratory.”
— Paragraph 33(b), Count 1: Failure to Conduct Hazardous Waste Determinations

• This passage confirms that ContiTech allowed multiple categories of hazardous and toxic chemicals to accumulate in the laboratory in an uncontrolled pile, without any waste determination having been performed to identify what those materials were or how dangerous they were.
• The waste codes cited span ignitable waste (D001), corrosive waste (D002), waste solvents (D035, F005), and specific toxic chemical products (U002 is acetone, U154 is methanol, U220 is toluene, U239 is xylene). This is a cocktail of flammable, toxic solvents, not a corner full of old paper.
• The solidified spill proves this pile was not recently created. Something leaked, and it sat there long enough to dry solid before the EPA ever set foot in the building.

“Eight (8) 1-gallon and seven (7) 1-quart containers of dough (D001, D035, and F005) under the fume hood in the laboratory, unmarked and undated, but estimated to have been present for at least two and a half (2.5) years.”
— Paragraph 41(b), Count 2: Operating Without a RCRA Permit

• Federal law requires hazardous waste to be removed or properly managed within 90 days. Two and a half years is approximately 912 days, more than ten times the legal accumulation limit.
• These containers had no date and no hazardous waste label, which means there was no mechanism in place to even track when the 90-day clock started. The containers were effectively invisible to the company’s own management system.
• The waste codes (D001: ignitable, D035: methyl ethyl ketone, F005: spent non-halogenated solvents) mean these were genuinely flammable and toxic materials stored improperly in a workspace where people were present daily.

“At the time of inspection, Respondent had no records for inspections conducted of the hazardous waste accumulation area in the OSS room for 2022, and only a small number of records of inspections conducted of the OSS room for 2023.”
— Paragraph 49, Count 2: Failure to Conduct Weekly Hazardous Waste Inspections

• The law requires Large Quantity Generators to inspect hazardous waste storage areas at least once per week, checking for leaks, corrosion, and deterioration. There are approximately 52 such required inspections per year.
• For the entire year of 2022, ContiTech produced zero records of compliance with this requirement in the OSS room. Zero. The company either performed no inspections, or performed them and documented nothing, and either answer is a failure.
• The OSS room is the same room where inspectors found multiple unlabeled 55-gallon drums, a container of “Tar” that had exceeded its legal storage limit, and a hand-labeled “Old Waste Thinner” container that had been sitting for over a year.

“Respondent had at least three (3) facility personnel whose positions relate to hazardous waste management that had not completed the annual review of the initial hazardous waste training.”
— Paragraph 56, Count 2: Failure to Perform Annual Review of Hazardous Waste Training

• Large Quantity Generators are required by law to ensure that employees who handle hazardous waste complete an annual refresher training. ContiTech confirmed at least three such employees had not done so at the time of the inspection.
• Beyond the missing annual reviews, the company had no written job descriptions for hazardous waste roles and no written descriptions of what training those roles required. The training system had no documented framework at all.
• Workers handling flammable solvents, toxic chemical waste, and large drums of used oil were doing so without documented evidence of the hazard-response preparation the law requires them to have.

“An oil-based rubber cement (D001) on the walls, equipment, floor, and floor grating of the Long V Cement House.”
— Paragraph 43, Count 2: Failure to Contain Hazardous Waste

• D001 is the EPA designation for ignitable hazardous waste, meaning material capable of catching fire or causing fire. Rubber cement containing flammable solvents coating the walls, floor, and equipment of a manufacturing area is not a minor housekeeping issue.
• The law requires hazardous waste to be placed in proper containers during accumulation. Coating the physical structure of a workspace is the opposite of containment. It is the definition of uncontrolled release within the facility.
• Workers entering and working in the Long V Cement House were being exposed to an ignitable hazardous substance that had been allowed to coat their work environment, with no documentation that anyone had inspected the space for this hazard.

Who Actually Pays When Corporate Compliance Is Optional

Environmental Degradation

The documented conditions at the ContiTech Lincoln facility represent direct, uncontrolled environmental hazards inside a functioning industrial workplace. Several violations describe scenarios where contamination had already occurred or was actively ongoing at the time of inspection.

• Ignitable rubber cement (D001) was documented coating the walls, floor, equipment, and floor grating of the Long V Cement House. This constitutes an uncontrolled release of a classified ignitable hazardous waste within the facility, with the potential for airborne solvent vapors to affect both workers and the air quality in surrounding areas.
• At least one spill of hazardous chemical waste had occurred inside the laboratory chemical pile and was left to solidify in place rather than being cleaned up or reported. Under RCRA, spills of hazardous waste require specific response procedures. None were followed.
• Multiple 55-gallon satellite accumulation containers were found with unlatched funnels rather than sealed lids, meaning volatile hazardous waste was open to the air in production areas of the plant. Fume hood placement of open containers does not fully mitigate the risk of evaporative release of toxic solvents.
• The definition of “disposal” under Nebraska environmental law includes spilling, leaking, or placing hazardous waste into any environment. The solidified spill and the rubber cement coating on facility surfaces arguably meet this definition, meaning the illegal disposal of hazardous material had already occurred inside the building.
• Universal waste (fluorescent lamps containing mercury) had been accumulating since at least December 15, 2023, in a container described as bearing “many different accumulation dates,” suggesting a pattern of ongoing non-compliant storage of a mercury-containing regulated waste for longer than one year.

Public Health

The workers inside the ContiTech Lincoln facility bear the most direct and undeniable public health risk from these documented failures. The community surrounding the plant at 4021 N 56th Street, Lincoln, Nebraska carries secondary risk.

• Workers in the laboratory were present in a space containing open, improperly stored containers of ignitable solvents (D001, D035), acetone (U002), methanol (U154), toluene (U220), and xylene (U239). Toluene and xylene are well-documented neurotoxins with established occupational exposure limits; methanol causes blindness and death at sufficient exposure levels. Containers were not all closed, and some were lying on their sides.
• Workers in the Long V Cement House performed their jobs in a space where ignitable rubber cement had coated the floor, walls, and equipment. Exposure to solvent-based cement vapors in an enclosed industrial space is a documented cause of occupational respiratory harm, central nervous system effects, and skin absorption of toxic chemicals.
• At least three employees whose roles involved managing these hazardous materials had not completed the mandatory annual refresher training the law requires. These individuals may not have known the correct response procedures if a spill, fire, or release event had occurred during their shifts.
• No written job descriptions for hazardous waste management roles and no documented training frameworks existed at the facility. This means there was no institutional baseline ensuring any specific employee knew what they were responsible for, or what hazards they were expected to manage.
• Weekly inspections of the OSS room, which housed multiple large drums of toxic and ignitable waste, produced zero records for the full year of 2022. Any leak, corrosion event, or container failure that occurred in that space during 2022 would have gone undetected and unreported under this inspection regime.
• The fluorescent lamp universal waste container was unlabeled (the document states it was “not properly marked or labeled”). Mercury-containing lamps improperly stored and unlabeled represent a contamination risk if the container is damaged, broken, or mishandled by workers who have not been told what they are handling.

Economic Inequality

The financial structure of this case illustrates exactly how the compliance system works for large industrial corporations versus how it works for everyone else.

• ContiTech USA, LLC is a Delaware-organized subsidiary of Continental AG. Continental AG reported revenues exceeding $45 billion in 2023. The $153,174 penalty assessed here represents approximately 0.00034% of that annual revenue. For a household earning $60,000 per year, the equivalent fine would be about $0.20 cents.
• The maximum statutory penalty per day per violation under RCRA is $124,426 as of January 2025. The EPA documented violations including materials estimated to have been stored illegally for approximately 912 days, containers present since at least January 2024 and May 2024, and an entire year of missing inspection records. The theoretical maximum penalty exposure vastly exceeds what was actually assessed.
• The Consent Agreement explicitly states the civil fine is not tax deductible. However, the legal and compliance costs incurred by ContiTech to negotiate and finalize this settlement through Thompson Hine LLP, a major corporate law firm, are ordinary business expenses that can typically be deducted. The workers who bore the environmental and health risks of this facility’s practices received no compensation or remedy under this settlement.
• The settlement resolves only the specific violations cited. The EPA’s reservation of rights language confirms the agency retains authority to pursue further action for any other violations or for any imminent endangerment conditions. Workers and residents cannot independently compel that action. They must rely on the same regulatory agency that accepted $153,174 to close the case on conduct spanning at least several years.
• Community members living near 4021 N 56th Street in Lincoln, Nebraska had no formal mechanism to participate in, object to, or even be notified of this settlement before it was finalized. The administrative consent agreement process is between the government and the corporation. The public learns about it afterward, if they learn about it at all.

What The Fine Actually Means In The Real World

Workers breathed solvent vapors and navigated floors coated in ignitable waste. The company paid a penalty smaller than the annual salary of one mid-level compliance officer. No worker received a cent.

How To Push Back: Names, Agencies, And Actual Steps

ContiTech USA, LLC signed this order on December 19, 2025. The settlement is closed. But the EPA’s own language reserves full rights to pursue further action, and several regulatory bodies maintain ongoing authority over this facility and its parent corporation.

Who Signed and Who Is Accountable

• David Cozad, Director of the Enforcement and Compliance Assurance Division, EPA Region 7, signed the Consent Agreement on December 19, 2025. His division sets the terms of corporate settlements in this region.
• Kate Vetterick, Office of Regional Counsel, EPA Region 7, served as the government attorney on the case. Contact: vetterick.kate@epa.gov
• Edwin Buckner, Enforcement and Compliance Assurance Division, EPA Region 7, is listed as a case contact. Contact: buckner.edwin@epa.gov
• Karina Borromeo, Regional Judicial Officer, EPA Region 7, issued the Final Order on December 23, 2025.
• Joel Eagle of Thompson Hine LLP (joel.eagle@ThompsonHine.com) served as legal counsel for ContiTech USA, LLC. Thompson Hine is a major corporate law firm representing the respondent’s interests throughout this process.
• The specific corporate title of the ContiTech USA, LLC representative who signed and legally bound the company to this agreement is [REDACTED – Not in Source]. The document confirms a representative with full legal authority executed the consent agreement.

Regulatory Watchlist

• EPA Region 7, Enforcement and Compliance Assurance Division: The primary federal enforcement body on this case. Region 7 covers Nebraska, Iowa, Kansas, and Missouri. File complaints about ongoing violations at the ContiTech Lincoln facility directly with this office.
• Nebraska Department of Environment and Energy (NDEE): The state-level co-enforcer. Nebraska holds EPA-delegated RCRA authority and has its own enforcement powers. Contact: ndeq.epainspections@nebraska.gov or jeffery.edwards@nebraska.gov
• OSHA (Occupational Safety and Health Administration): If workers at the Lincoln facility experienced or continue to experience unsafe exposure to flammable, toxic, or corrosive substances without proper training or hazard communication, OSHA holds separate jurisdiction and accepts confidential worker complaints at 1-800-321-OSHA.
• DOJ Environment and Natural Resources Division: For cases where civil penalties are insufficient and criminal prosecution for environmental violations may be warranted, the DOJ’s environmental crimes section maintains separate authority independent of EPA civil settlements.

What You Can Do Right Now

• If you live near 4021 N 56th Street in Lincoln, Nebraska, or work at the ContiTech facility, you have the right to request the full inspection report from EPA Region 7 or the Nebraska NDEE under Freedom of Information Act (FOIA) or Nebraska’s public records statutes. The more public this stays, the harder it is to ignore.
• Contact Lincoln-area environmental justice organizations and ask them to monitor the ContiTech facility for ongoing compliance. Organizations focused on industrial pollution in working-class neighborhoods can file public records requests, attend community meetings, and apply sustained pressure that outlasts any single news cycle.
• Share this article with anyone who works in manufacturing or industrial settings in Nebraska. Worker-to-worker education about hazardous waste rights, including the right to know what chemicals are present and the right to a safe workplace, is one of the most effective tools available when regulatory enforcement settles for pennies on the dollar.
• Contact your Nebraska state legislators and demand that state-level RCRA enforcement budgets are funded adequately to conduct inspections more frequently than once every several years at large quantity hazardous waste generators. The Lincoln facility registered as an LQG in 2017 and was inspected in 2025. That is an eight-year gap.
• If you are a ContiTech worker or former worker who has health concerns related to solvent or chemical exposure at this facility, connect with occupational health legal advocates and document your experiences. The settlement explicitly does not extinguish claims related to chemical exposure at the facility.