The Non-Financial Ledger

Picture the kind of place that doesn’t make the news. An industrial park on a road that shares its name with industry itself, in a small borough in Armstrong County, Pennsylvania, population around 2,200. Leechburg is the kind of western Pennsylvania town that built itself on rivers, railroads, and manufacturing. The people who live within a few miles of 1153 Industrial Park Road probably don’t spend much time thinking about what’s processed behind those walls. Most people don’t. That’s how it works.

Inside that facility, workers handle some of the most reactive and toxic materials in industrial manufacturing. Lead. Nickel. Copper. Indium. Silver. Gold. These aren’t abstract chemical names on a regulatory form. Lead causes irreversible neurological damage. Nickel compounds are classified as human carcinogens. Copper and its derivatives destroy aquatic ecosystems at concentrations measured in parts per billion. These chemicals don’t stay put when storage containers are left open, unlabeled, or crammed into a room without a clear path for anyone to get in and do something about a spill.

What the EPA inspection found in August 2023 was not a facility trying and falling short. It was a facility where the most basic rules, the ones that exist specifically to prevent a bad situation from becoming a catastrophe, had been quietly skipped for years. Thirty weeks of missing inspection logs. Thirty-six containers of hazardous waste packed into a single plate room without enough space for a person to walk between them. Two 5,000-gallon basement tanks full of nickel-copper solution with no hazardous waste label. A lid sitting loose on a container of tin-lead bath filters because it couldn’t be secured.

The people most exposed to this negligence are the workers on those plating lines, the first responders who would be called to Industrial Park Road if something went wrong, and the residents downstream of a drainage system connected to a facility that treated hazardous waste. None of them signed up to absorb that risk. None of them had access to the inspection logs that would have shown them the gaps. The EPA did not review those logs until an inspector walked through the door in August 2023. By then, the pattern was already years old.

The penalty is $53,220. That number means almost nothing to the people who bore the actual risk. It is a line item, a resolved docket, a filing dated January 29, 2026. The community near Leechburg gets none of it. It goes to the federal government. And the company, under the terms of the settlement, neither admits nor denies the facts that the EPA documented in its own inspection report.

Legal Receipts: What the Documents Actually Say

Every quote below is pulled verbatim from the EPA Consent Agreement and Final Order, Docket No. RCRA-03-2026-0063, filed January 29, 2026.

“Respondent owns and operates a facility… that engages in metal parts electroplating and coating for semiconductor, automotive, telecommunications, and military components. Respondent’s primary hazardous wastes consist of Tin-Tin/Lead spent solutions (D002); Copper/Nickel plating bath solutions (D002); Indium plating bath solutions (D002); plating bath filters for silver (F007, D011, D003), gold (F007, D003), and nickel; spent carbon filters from the wastewater treatment unit (F006, F007); WWTU filter press sludge (filter cake) (F006, F007); trench sludge from the subfloor trench system connected to the WWTU (F006, F007).” Paragraph 15, Consent Agreement

“At the Inspection, a full container labeled as hazardous waste ‘Sn/Pb Waste’ in the accumulation area of Plate Room #3 was marked with an accumulation start date of May 2, 2023. Based on the accumulation start date, Respondent had been accumulating the hazardous waste for 113 days at the time of the Inspection (August 22, 2023).” Paragraph 24(a)(i), Consent Agreement

“At the Inspection, there were approximately twenty-nine (29) 55-gallon containers, five (5) 30-gallon containers, and two (2) 5-gallon containers placed together in a cordoned off space without aisle space between the containers in the hazardous waste accumulation areas of Plate Room #3.” Paragraph 24(b)(i) and Paragraph 29, Consent Agreement

“Two (2) 5,000-gallon tanks in the basement marked as ‘Tank 1’ and ‘Tank 2’ along with ‘Nickel Copper Solution’ and ‘Direct Use/Reuse’ but no marking of ‘Hazardous Waste’ or other indication of the hazards of the contents, which was shipped offsite as D002 hazardous waste.” Paragraph 24(c)(i), Consent Agreement

“EPA inspectors observed 30 calendar weeks where no inspection was documented… Over the course of 34 weeks in 2021 through 2023, Respondent violated 25 Pa. Code § 264a.1… by failing to inspect, at least weekly, areas where hazardous waste containers are stored.” Paragraphs 45 and 46, Consent Agreement

“From the time of the Inspection through January 17, 2025, Respondent violated 25 Pa. Code § 264a.1… when it failed to designate a primary emergency coordinator when more than one individual is listed as an emergency coordinator in the contingency plan.” Paragraph 36, Consent Agreement

Societal Impact Mapping

Environmental Degradation

The facility’s hazardous waste streams are directly connected to the surrounding environment through its physical infrastructure, and the documented violations created conditions for undetected releases.

• The facility operates a subfloor trench system physically connected to a wastewater treatment unit. Hazardous sludge, designated F006 and F007, accumulates in these below-floor trenches. Any undetected leak or structural failure in this system would feed directly into the connected drainage infrastructure.
• Thirty-plus weeks of skipped container inspections across 2021-2023 means the company had no contemporaneous record of whether its drums were leaking or corroding during those periods. Leaks found only at the annual inspection are leaks that may have been releasing for weeks.
• The two 5,000-gallon basement tanks of corrosive nickel-copper solution, marked “Direct Use/Reuse,” were not designated as hazardous waste on-site despite being shipped off as D002 hazardous waste. The D002 corrosivity code applies to materials with a pH of 2 or below, or 12.5 or above, or capable of corroding steel at a rate greater than 6.35 millimeters per year. These were the largest storage volumes at the facility.
• Tin, lead, copper, nickel, silver, and indium, all generated as waste at this facility, are heavy metals and metal compounds documented to persist in soil and sediment, bioaccumulate in aquatic food chains, and cause long-term ecological damage at concentrations far below what is visible or detectable without monitoring equipment.

Public Health

The violations documented at the Leechburg facility are not abstract regulatory failures. Each one corresponds to a specific category of physical harm that the regulation exists to prevent.

• Lead, designated by waste code D003 (reactive) and present in tin-lead spent solutions, tin sludge, and bath filters, is a neurotoxin with no established safe exposure level. Children within a contamination radius of a lead release face permanent IQ reduction, behavioral changes, and developmental delays. The container of lead waste that sat 23 days past its legal accumulation limit was in an area with blocked emergency access.
• Nickel compounds are classified as Group 1 human carcinogens by the International Agency for Research on Cancer. The facility generated nickel-containing sludge (F006), spent nickel plating bath filters, and nickel-copper floor water, all handled in conditions documented to be non-compliant with containment rules.
• Workers on the plating lines at this facility are the people most directly exposed to these materials. The failure to maintain aisle space means that if a drum failed during a shift, the workers nearest it could not be rapidly reached by emergency responders. A 55-gallon drum of corrosive nickel-copper solution tipping in a room with no walkways is not a recoverable situation.
• The failure to designate a primary emergency coordinator means that in a real chemical emergency at the facility, the three people listed in the contingency plan would have had no clear legal authority to make the first call. That delay, measured in minutes, determines outcomes in chemical exposure incidents.
• Indium and its compounds, present in the facility’s plating bath waste, are classified as potentially hazardous to the kidneys and respiratory system with evidence of pulmonary toxicity in occupational settings. Indium lung, a form of interstitial lung disease, has been documented in workers at indium-processing facilities.

Economic Inequality

The $53,220 penalty reveals a structural imbalance in how environmental risk is distributed and how enforcement economics work against the communities that bear the most exposure.

• Leechburg Borough had a median household income of approximately $39,000 in recent census estimates, well below both the Pennsylvania and national medians. Industrial facilities of this type concentrate near lower-income communities because land is cheaper and political resistance is lower. The people most economically unable to relocate away from industrial risk are the ones living closest to it.
• A $53,220 penalty against a company running a multi-stream hazardous waste operation serving semiconductor, automotive, telecom, and military clients represents a fraction of the facility’s annual revenue. It functions as a cost of doing business rather than a deterrent. Nothing in the consent agreement requires the company to fund any community health monitoring, environmental remediation, or worker compensation for the period of non-compliance.
• Workers at the facility, who were exposed to the conditions described in the inspection report, have no mechanism under this consent agreement to access compensation, medical monitoring, or even information about what they were exposed to and when. The settlement resolves the EPA’s civil penalty claims only; it does not address worker health or community remediation.
• The legal structure of the settlement, under which the respondent “neither admits nor denies” the factual allegations, forecloses the most direct path for any civil litigation by affected parties. A company that has not “admitted” any facts in a regulatory settlement is in a stronger defensive position if a former worker or community member attempts to establish exposure liability in a separate proceeding.

The “Cost of a Life” Metric

What Now?

The consent agreement is signed, the penalty is set, and the company has certified it is now in compliance. Here is what accountability actually requires from every stakeholder who has the power to demand more.

Key Corporate Roles Named in the Document

• Shane Casperson, VP of Engineering: The individual named in the Certificate of Service as the recipient of the Consent Agreement and Final Order on behalf of the respondent. He is the listed point of contact at the Leechburg facility address.
• Respondent’s Legal Counsel Contact: Identified by the email address scasperson@composidie.com, suggesting an affiliation with a company named Composidie. The source document does not name additional corporate officers or board members.

Regulatory Watchlist

• EPA Region 3 (Philadelphia): The lead enforcement body on this case. Future compliance evaluations of the Leechburg facility fall under their jurisdiction. Contact: U.S. EPA Region 3, 1650 Arch Street, Philadelphia, PA 19103.
• Pennsylvania Department of Environmental Protection (PADEP): The state agency that administers the authorized hazardous waste program in lieu of the federal program. The EPA notified PADEP of this action by letter on March 11, 2024. PADEP has independent authority to enforce Pennsylvania hazardous waste regulations.
• Occupational Safety and Health Administration (OSHA): RCRA violations involving blocked emergency access and improperly sealed containers of toxic chemicals also implicate worker safety standards under OSHA’s Hazard Communication Standard and emergency response rules. This case was not adjudicated as a worker safety matter. That does not mean worker safety was not affected.
• EPA Office of Inspector General (OIG): If you believe EPA enforcement in this matter was insufficient or the penalty was inappropriately reduced, the OIG accepts complaints about EPA enforcement decisions at oig.epa.gov.

What You Can Do

• File a PADEP complaint: Pennsylvania residents can report environmental concerns directly to PADEP at 1-800-541-2050 or online at dep.pa.gov. If you live near Leechburg and have observed anything at the Industrial Park Road facility that concerns you, that is a documented report in the state system.
• Request facility records: The EPA’s Envirofacts database (enviro.epa.gov) and PADEP’s eFACTS database contain publicly available records for RCRA-regulated facilities. Look up EPA ID No. PA0000381921 to track the facility’s compliance history.
• Support Armstrong County mutual aid networks: Environmental justice organizing in rural western Pennsylvania is under-resourced. Connect with Pennsylvania environmental groups such as the Clean Air Council, PennEnvironment, or local watershed associations working in the Allegheny River basin, which drains the Leechburg area.
• Demand health monitoring: Contact the Armstrong County Health Department and your state legislators to request that any renewal of permits for this facility include mandatory community health and environmental monitoring provisions. The consent agreement requires none.
• Share this document: The full Consent Agreement and Final Order is a public record. Use it. Put it in front of your local newspaper, your city council representative, your union chapter. The only version of this story that leads to accountability is the one more people read.