The Non-Financial Ledger

McCook, Illinois is a working-class industrial suburb just southwest of Chicago. The people who live there breathe the same air and drink from the same watershed as the railroad yards, warehouses, and heavy industrial operations that surround them. They are not abstract bystanders. They are neighbors.

On December 14, 2021, a real estate development company called Bridge Point McCook 3, LLC purchased 87 acres of former railroad land in their neighborhood. With that purchase came a legal obligation: account for the hazardous waste on the property and handle it according to the rules that exist specifically to keep communities like McCook safe. Those rules are not arbitrary paperwork. They were written because uncontrolled hazardous waste kills people. It contaminates groundwater. It causes fires. It releases toxins that accumulate in children’s bodies for decades.

Bridge Point held that waste for 143 days without a permit. For 53 days beyond the legal limit, the hazardous material sat on that site with no contingency plan in place. If there had been a spill during those months, there was no documented procedure for containing it. Nobody on staff had received the hazardous waste training the law requires. The community of McCook had no way of knowing any of this was happening, because the company also never filed the annual report that would have put this information in front of regulators on time.

When they did finally ship the waste off-site, they did it under the name of the previous owner, Progress Rail Locomotive, Inc., using that company’s federal identification number. The EPA’s hazardous waste tracking system exists so that regulators can follow dangerous materials from cradle to grave. Bridge Point short-circuited that system. The paper trail for 3,426 pounds of hazardous waste pointed to a company that no longer owned the site.

Nobody in McCook was consulted. Nobody was warned. The penalty that resolved five simultaneous federal violations was $7,500. That is less than many people in that zip code make in a month. It will not show up in Bridge Point’s quarterly earnings. It will not deter the next developer from running the same calculation.

Legal Receipts: Their Own Words

These are not allegations from outside critics. The following quotes come directly from Bridge Point McCook 3, LLC’s own written responses to the EPA, and from the settlement agreement itself. The company said these things in writing, under threat of civil and criminal penalties for false statements.

“Bridge stored the above waste for 143 days from generation date and Respondent had not obtained a permit, interim status nor an extension of the 90-day period.”

— EPA Docket No. RCRA-05-2024-0016, Section 2(A)(i)

“A Contingency Plan, Emergency Action Plan, or equivalent Spill Prevention, Control, and Countermeasures Plan had not been prepared for the Facility.”

— Respondent’s own statement, October 3, 2023 (as cited in settlement)

“The Bridge facility did not have a RCRA contingency plan that meets all the requirements in 35 IAC 722 Subpart M.”

— Respondent’s own statement, March 29, 2024 NOV response (as cited in settlement)

“Annual reports have not been submitted.”

— Respondent’s own statement, October 3, 2023 (as cited in settlement)

“Respondent shipped hazardous waste offsite on April 27, 2022 (014521312 FLE) and May 6, 2022 (014521307FLE and 01451309 FLE) under the prior owner’s name Progressive Rail – McCook with an ID of ILD006009600.”

— EPA Docket No. RCRA-05-2024-0016, Section 2(D)

Societal Impact Mapping

Public Health

The 143-day window of unpermitted hazardous waste storage at 9130 W. 55th St. in McCook, Illinois created documented regulatory risk for the surrounding residential and industrial community.

• The facility stored hazardous waste for 53 days beyond the legal maximum with zero emergency response infrastructure in place. Any accidental release during that period, from spill, fire, or container failure, would have occurred with no documented containment procedure and no designated emergency coordinator.
• The company’s own admission confirmed no Spill Prevention, Control, and Countermeasures Plan existed. This class of plan is specifically designed to prevent hazardous materials from reaching waterways and soil. McCook sits within the broader Chicago metro watershed. A release without containment measures is a contamination event waiting for a trigger.
• None of the facility’s personnel had received hazardous waste management training. Workers handling or working near hazardous materials without training are at direct personal risk of exposure, and they lack the knowledge to recognize signs of leakage, container degradation, or a developing emergency.

Economic Inequality

The financial and legal asymmetry in this case follows a familiar pattern: a well-capitalized real estate developer operating outside the law in a working-class community, settling for a penalty that costs less than a rounding error.

• Bridge Point McCook 3, LLC purchased 87 acres of industrial land for demolition and redevelopment. This is a capital-intensive, high-margin business. The $7,500 penalty represents a cost of compliance failure so small it functions as an incentive to cut corners rather than a deterrent.
• The EPA’s own settlement agreement states both parties agreed the $7,500 figure “is in the public interest.” The residents of McCook, who bore the risk of five simultaneous hazardous waste law violations, were not party to that agreement and had no seat at the table.
• The hazardous waste generated at this site came from a former Progress Rail Locomotive facility. Historically, industrial land in communities like McCook accumulates contamination across successive owners, each of whom negotiates liability individually with regulators. The community absorbs cumulative exposure while each corporate owner pays one-time, discounted settlements.
• Bridge Point’s penalty is not tax deductible under the agreement’s terms. However, $7,500 is such a negligible figure in the context of an 87-acre industrial real estate transaction that its non-deductibility carries no practical deterrent weight.

The “Cost of a Life” Metric

What Now?

The settlement is signed and the penalty is paid, but the EPA explicitly reserved all rights to pursue Bridge Point for past, present, or future violations. Here is who holds accountability going forward, and what you can do.

Key Parties of Record

• Vice President, Bridge Point McCook 3, LLC Nick Siegel signed the settlement agreement on July 2, 2024, certifying that violations were corrected and the penalty was paid.
• EPA Region 5 Division Director Michael D. Harris approved the settlement on behalf of the EPA’s Enforcement and Compliance Assurance Division.
• EPA Region 5 Regional Judicial Officer Ann L. Coyle signed the Final Order on July 26, 2024, making it effective immediately.
• EPA Contact: Land Enforcement Branch Andrea Dierich (Dierich.andrea@epa.gov) at the EPA Region 5 Land Enforcement and Compliance Assurance Branch handled this case. Future violations at this site should be directed there.

Watchlist: Regulatory Bodies With Ongoing Jurisdiction

• EPA Region 5 (Chicago): Retains all enforcement rights for any future RCRA violations by Bridge Point at this or any other facility. The settlement agreement explicitly preserves these rights.
• Illinois EPA: The violations also implicated Illinois hazardous waste management code (Ill. Admin. Code tit. 35). The Illinois EPA received notice of this action and retains independent enforcement authority under state law.
• EPA Office of Inspector General: If you believe enforcement penalties are systematically too low to deter corporate actors in your community, the OIG accepts public complaints about EPA enforcement adequacy.
• DOJ Environment and Natural Resources Division: For cases where civil penalties fail to achieve compliance, the DOJ can pursue criminal RCRA enforcement. This case was settled civilly; criminal referral was not made.

What You Can Do

• File a FOIA request with EPA Region 5 for any additional inspection records, correspondence, or prior NOVs related to EPA ID No. ILR000215186 or the McCook site at 9130 W. 55th St. to see what else may have occurred.
• Contact your Cook County representative and demand they push the Illinois EPA to implement stronger hazardous waste oversight for industrial real estate transactions, specifically the gap between property transfer and permit compliance.
• Connect with local environmental justice organizations in the southwest Chicago suburbs. Groups monitoring industrial contamination in communities like McCook, Cicero, and Stickney have ongoing campaigns that need bodies and attention.
• Attend McCook Village Board meetings and ask directly what the village’s notification protocol is when the EPA opens a hazardous waste investigation at a local facility. You have a right to know what is happening in your neighborhood.
• Share this record: Bridge Point McCook 3, LLC is an active real estate developer. Workers, neighbors, and future tenants of any Bridge Point property have a right to know how this company handled its first environmental obligation under federal law.