Corporate Misconduct Accountability Project | Environmental Enforcement
BREAKING: Holbrook Auto Parts-YPSI LLC fined $1,371.50 for hazardous waste violations • 62.97 TONS of D008 hazardous waste shipped without required notifications • EPA Region 5 issued Consent Agreement and Final Order, January 22, 2026 • Facility has since ceased operations • Ypsilanti, Michigan •
Holbrook Auto Parts-YPSI, LLC · EPA Enforcement Order · 2021-2026
Holbrook Auto Parts Shipped 63 Tons of Toxic Waste and Told Nobody
A Ypsilanti auto parts facility generated more than a thousand kilograms of hazardous lead waste per month and violated federal notification and reporting laws for years before regulators caught up with them.
🟡 HIGH SEVERITY
TL;DR
Holbrook Auto Parts-YPSI, LLC at 2574 State Street in Ypsilanti, Michigan generated over 1,000 kilograms of D008 hazardous waste (lead-contaminated material) per month in 2021, qualifying as a Large Quantity Generator under federal law. They shipped more than 62 tons of this toxic waste off-site without ever filing the required notification to regulators, and failed to submit the legally required Biennial Report in 2022. Federal law exists precisely to track where toxic waste goes. Holbrook ignored it entirely. The company has since shut down, but the EPA still pursued accountability, extracting a $1,371.50 penalty.
Demand that all waste generators, large and small, face real consequences when they hide toxic materials from public oversight. Communities deserve to know what dangers are moving through their neighborhoods.
62.97
Tons of D008 hazardous waste shipped off-site
$1,371
Civil penalty assessed by EPA
1,000+ kg
Hazardous waste generated per month in 2021
2
Federal violations cited (RCRA notification and reporting)
⚠️ The Violations: A Breakdown
Core Allegations
What they did
| 01 | Holbrook Auto Parts generated 1,000 kilograms or more of D008 hazardous waste (lead-based material) per month in 2021, legally qualifying the facility as a Large Quantity Generator under the Resource Conservation and Recovery Act. | high |
| 02 | On January 12, 2021, the company shipped approximately 62.97 tons of D008 hazardous waste off-site using Manifest Tracking Numbers 020134267JJK and 020134268JJK, without ever notifying the State of Michigan of its Large Quantity Generator status. | high |
| 03 | Federal law requires generators to file notification when their hazardous waste activity changes to Large Quantity Generator status. Holbrook failed to submit this notification in direct violation of Section 3010(a) of RCRA, 42 U.S.C. Section 6930(a). | high |
| 04 | Holbrook also failed to prepare and submit a Biennial Report to the State of Michigan by March 1, 2022, covering its 2021 hazardous waste generation activities, in violation of Michigan Administrative Code R 299.9312(1). | high |
| 05 | The facility’s actions and processes caused the production of hazardous waste as defined under Michigan and federal law. The land and structures at 2574 State Street were used for treating, storing, or disposing of hazardous waste. | medium |
Regulatory Failures
How oversight broke down
| 01 | The federal RCRA notification system depends entirely on generators self-reporting their waste activity status. Holbrook’s failure to report demonstrates exactly how this honor-system approach creates dangerous blind spots in environmental oversight. | high |
| 02 | EPA did not discover the violation through inspections or active monitoring. The agency issued a Notice of Violation only on May 20, 2024, more than three years after the actual violation in 2021. | high |
| 03 | The state of Michigan has been authorized to administer its own hazardous waste program since 1986, yet this Ypsilanti facility evaded both state and federal oversight for years, revealing significant gaps in enforcement capacity. | medium |
Corporate Accountability Failures
Weak penalties and no structural change
| 01 | The $1,371.50 civil penalty is the final penalty assessed against Holbrook Auto Parts. For a company that shipped nearly 63 tons of hazardous waste without telling anyone, this amount functions less as punishment and more as a bureaucratic formality. | high |
| 02 | The EPA reduced the penalty after analyzing Holbrook’s financial information and determining the company had “a limited ability to pay.” The facility closed in 2024 before the consent order was finalized. | medium |
| 03 | The consent agreement explicitly resolves only the company’s liability for federal civil penalties. The EPA retains the right to pursue injunctive, equitable, or criminal remedies for any other violations of law. | medium |
| 04 | Holbrook waived its right to request a hearing, contest the allegations, and appeal the order. No individual owner or operator faced personal accountability for the violations. | medium |
Public Health and Safety
What D008 waste means for communities
| 01 | D008 is the EPA’s hazardous waste code for lead-contaminated materials. Lead is a proven neurotoxin with no safe level of exposure, particularly dangerous for children, causing irreversible developmental damage, reduced IQ, and behavioral disorders. | high |
| 02 | The notification and biennial reporting requirements exist specifically to ensure regulators can track where toxic materials are going and whether they are being disposed of safely. Without this data, communities cannot assess whether they face contamination risks. | high |
| 03 | Ypsilanti, Michigan is a working-class community with historically limited resources to monitor corporate environmental compliance. Facilities like Holbrook Auto Parts disproportionately operate in communities that face the greatest barriers to demanding accountability. | medium |
🕐 Timeline of Events
Oct 30, 1986
Michigan granted final authorization by EPA to administer its own state hazardous waste program in place of the federal RCRA program.
Jan 12, 2021
Holbrook Auto Parts ships approximately 62.97 tons of D008 hazardous waste off-site using manifest tracking numbers 020134267JJK and 020134268JJK.
2021
Holbrook generates 1,000+ kilograms of D008 hazardous waste in some calendar months, qualifying as a Large Quantity Generator. No notification is filed with the State of Michigan.
March 1, 2022
Biennial Report deadline passes. Holbrook fails to submit the required report to the State of Michigan covering its 2021 hazardous waste activities.
May 20, 2024
EPA sends Holbrook a Notice of Violation and Opportunity for Settlement, identifying the RCRA violations and offering a streamlined settlement process.
Nov 20, 2024
Holbrook notifies EPA by email that the facility is no longer operating and has ceased operations in 2024.
Aug 28, 2025
Holbrook submits Site Identification Form (EQP5150) to the State of Michigan officially notifying that the company is out of business and no longer generating waste.
Jan 15, 2026
Simen Savaya, Owner of Holbrook Auto Parts-YPSI, LLC signs the Consent Agreement and Final Order.
Jan 22, 2026
EPA Acting Division Director Carolyn Persoon and Regional Judicial Officer Ann L. Coyle sign and file the final consent order. Holbrook must pay $1,371.50 within 30 days.
💬 Direct Quotes from the Legal Record
QUOTE 1
Scale of hazardous waste generated
Core Allegations
“In 2021, Respondent generated 1000 kilograms or greater of D008 hazardous waste in some calendar months (qualifying it as a ‘Large Quantity Generator’), which it shipped off-site to a treatment, storage or disposal facility within the United States.”
💡 This single sentence establishes both the scale of the problem and the company’s clear legal obligation to notify regulators, an obligation it ignored entirely.
QUOTE 2
Failure to notify on change to Large Quantity Generator status
Regulatory Failures
“In 2021, Respondent did not submit a notification of the change of the Facility’s type of hazardous waste activity to Large Quantity Generator status to the State, in violation of Section 3010(a) of RCRA, 42 U.S.C. Section 6930(a).”
💡 A direct citation of the specific federal law violated, making clear this was not a technicality but a core regulatory requirement the company bypassed.
QUOTE 3
63 tons shipped with no oversight
Core Allegations
“On January 12, 2021, Respondent shipped approximately 62.97 tons of D008 hazardous waste off-site for eventual disposal on Manifest Tracking Numbers 020134267JJK and 020134268JJK.”
💡 Nearly 63 tons of lead-contaminated material moved through Michigan roads and communities with no regulatory oversight because this company chose paperwork convenience over public safety.
QUOTE 4
Failure to file biennial report
Regulatory Failures
“In 2022, Respondent did not prepare and submit a Biennial Report to the State of Michigan by March 1 for the preceding calendar year, in violation of MAC R 299.9312(1).”
💡 The biennial report is the basic transparency document that tells regulators what a company did with its waste. Holbrook skipped this entirely, keeping the public in the dark.
QUOTE 5
Penalty reduced due to ability to pay
Corporate Accountability
“Complainant also considered U.S. EPA’s RCRA Civil Penalty Policy, dated June 23, 2003, and conducted an analysis of Respondent’s financial information and determined Respondent has a limited ability to pay.”
💡 The final $1,371.50 penalty was already a reduced figure based on financial hardship. The environmental harm caused by shipping 63 tons of lead waste invisibly cannot be measured in dollars this small.
💬 Commentary
Why does it matter that Holbrook didn’t file a notification? The waste was shipped to a legitimate disposal facility.
The notification requirement is not a technicality. It is the foundation of the entire hazardous waste tracking system. When a company reaches Large Quantity Generator status, regulators need to know so they can increase oversight, conduct inspections, and verify the waste is being handled safely. Without that notification, 63 tons of lead-contaminated material moved through Michigan with no federal or state eyes on it. The destination facility may have been legitimate, but the public had no way to verify that, and neither did regulators. That gap is exactly what bad actors exploit.
Is a $1,371.50 penalty a real punishment for this kind of violation?
No. It is not. The EPA reduced the penalty because Holbrook had limited ability to pay, which is a legitimate consideration under the law. But the practical effect is that a company can ship 63 tons of toxic lead waste without notifying anyone, operate for years before being caught, close down, and walk away with a fine smaller than most monthly car payments. This is not deterrence. Penalties of this scale send a message to other businesses that the cost of compliance may well exceed the cost of violation, particularly if they can claim financial hardship at the end.
What is D008 hazardous waste, and why does it matter to people living near auto parts businesses?
D008 is the EPA designation for hazardous waste containing lead above regulatory thresholds. Auto parts businesses commonly generate this waste through battery recycling, metal processing, and brake component handling. Lead is one of the most dangerous environmental toxins known: it accumulates in soil and groundwater, where it can enter the food chain, contaminate drinking water, and be inhaled as dust. Children are especially vulnerable, with lead exposure causing irreversible neurological damage including reduced IQ and behavioral disorders. Neighborhoods near facilities that mishandle lead waste face real, lasting harm, and they are disproportionately working-class communities with fewer resources to fight back.
What can I do to prevent this from happening again?
Several concrete actions can help. Contact your state environmental agency and ask for public disclosure of all Large Quantity Generator notifications in your area. Support organizations like Earthjustice, the Environmental Defense Fund, and local environmental justice groups that push for stronger enforcement. Demand that your elected representatives increase EPA enforcement budgets and raise minimum penalties for hazardous waste violations so that fines are not cheaper than compliance. If you live near a commercial facility, you can request inspection records through FOIA. You can also check EPA’s ECHO (Enforcement and Compliance History Online) database to see the violation history of facilities near you.
Why did it take three years for the EPA to issue a violation notice?
Because the system relies heavily on self-reporting. Holbrook was supposed to notify regulators when its waste generation crossed the Large Quantity Generator threshold. It did not. The EPA only discovered the violation when it reviewed the company’s records, likely triggered by manifest tracking data from the waste disposal facility. The three-year gap between the violation (January 2021) and the notice (May 2024) is a direct consequence of underfunded enforcement and an oversight model that trusts companies to police themselves. That trust was misplaced here, and it is misplaced regularly across the industry.
The CAFO can be found on the EPA’s website: https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/7762B00657E2B03085258D87006E002A/$File/RCRA-05-2026-0008_CAFO_HolbrookAutoParts_YpsilantiMichigan_10PGS.pdf
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