The Paper Trail: A Timeline of Unchecked Expansion

According to Environmental Protection Agency Docket No. CAA-03-2024-0060DA, Petroleum Management, Inc. built its facility for processing petroleum-contaminated waste at 5200 and 5218 Curtis Avenue in Baltimore back in 2011. The company then constructed additional process equipment in 2013, 2017, 2018, 2019, and 2020. Bulk storage tanks came online in 2014.

For years, this operation continued until an EPA on-site inspection in September 2020 triggered a formal investigation. The EPA’s findings allege that from 2014 until a fire shut down the facility on March 7, 2022, Petroleum Management operated as a “major source” of toxic air pollution without the federal permits required by the Clean Air Act.

The list of chemicals the EPA alleges the facility was a major source of reads like a hazardous materials warning label. It includes known or suspected carcinogens and toxic substances:

• Benzene
• Toluene
• Ethylbenzene
• Xylene (m, p, and o-isomers)
• Chloroform
• Methylene chloride
• Hexane
• And a dozen others listed in the official filings.

The Non-Financial Ledger: Poisoning a “Nonattainment” Zone

The EPA documents repeatedly state that Baltimore City is an ozone “nonattainment area.” This isn’t just bureaucratic jargon. It’s an official government designation that means the air you breathe there is already considered a threat to public health. The ground-level ozone, or smog, exceeds the National Ambient Air Quality Standards. The chemicals Petroleum Management is accused of releasing, Volatile Organic Compounds (VOCs), are primary ingredients in the chemical reaction that creates this smog.

Operating a facility that releases these pollutants in such an area requires extreme oversight. The entire point of the permitting system—the New Source Review (NNSR) and Title V permits the EPA alleges the company failed to obtain—is to prevent new pollution from making an already dangerous situation worse. By allegedly sidestepping this entire legal framework, the company offloaded the cost of compliance onto the lungs of Baltimore residents.

The fire that occurred on March 7, 2022, which shut down operations for over a year, stands as a stark physical reminder of the risks inherent in handling such materials. The EPA filing alleges a failure to operate “in a manner consistent with safety and good air pollution control practices for minimizing emissions.”

Legal Receipts: The Allegations in Black and White

The EPA’s Administrative Order lays out a series of specific alleged violations. These aren’t opinions; they are direct citations of federal and state environmental law that the company is accused of breaking for nearly a decade.

“Based on information available to the EPA, from 2014 to March 7, 2022, Respondent discharged VOC with a vapor pressure greater than 0.002 psia from its process equipment in excess of 20 pounds per day without reducing VOC discharge by 85% or more…”

“Based on information available to the EPA, from 2014 to March 7, 2022, Respondent failed to apply for or obtain any NNSR permits… prior to, during, or after the construction and/or major modifications of the Facility…”

The most revealing line itemizes the core of every corporate settlement. While agreeing to a list of corrective actions, Petroleum Management leverages a common legal tactic to avoid liability.

“Respondent neither admits nor denies the findings in Section C (Findings) of this Order.”

Societal Impact Mapping: A System Designed to Fail

Public Health

The alleged emissions are directly linked to severe health consequences. Benzene is a known human carcinogen. Toluene can cause nervous system damage. Ground-level ozone, which VOCs help create, exacerbates asthma, bronchitis, and other respiratory illnesses. For eight years, these materials were allegedly released into a community without the pollution controls and monitoring that a Title V permit would have mandated.

Environmental Degradation

Smog damages more than human health. It harms sensitive vegetation, damages forests, and reduces crop yields. The ecosystem of the Chesapeake Bay area is already under immense pressure; adding uncontrolled industrial pollutants only increases that burden.

Economic Inequality

This is a story of privatized profits and socialized costs. A corporation allegedly saved money by not installing pollution controls, not paying for permits, and not hiring compliance staff. The public, specifically the residents of Baltimore, paid the price through degraded health, a dirtier environment, and the risk of industrial accidents like the 2022 fire. This is the predictable outcome of a system where regulatory capture and weak enforcement allow corporations to treat communities as sacrifice zones.

The Cost of Non-Compliance

Under the Maryland State Implementation Plan, any facility that has the potential to emit 25 tons per year (TPY) of VOCs or NOx is classified as a “major stationary source.” This classification triggers the most stringent permitting requirements. The EPA’s entire case rests on the allegation that Petroleum Management crossed this line and simply chose not to file the paperwork or follow the rules that came with it.

What Now? The Watchlist.

The “Administrative Compliance Order on Consent” means the company must now act. This is the resistance—the result of regulatory enforcement. They did not volunteer to do this.

Corporate Roles

The Owner and Operator of Petroleum Management, Inc. are ultimately responsible for the facility’s compliance.

Regulatory Watchlist

• EPA Region 3: The federal agency that brought this enforcement action. Their continued oversight is critical.
• Maryland Department of the Environment (MDE): The state agency that co-regulates air quality. The order requires the company to submit all future reports and permit applications to them.

Grassroots Resistance

The order mandates the installation of new air monitors, monthly sampling of storage tanks, and quarterly reports to the EPA and MDE. This creates a public paper trail that did not exist before. True accountability comes from community vigilance. Support local environmental justice organizations in Baltimore that monitor industrial polluters and pressure regulators to enforce the law. A consent order is not justice; it is the starting line for forcing compliance. It is up to us to make sure they, and the regulators, finish the race.