TL;DR
- Viant Collegeville, LLC — a Pennsylvania manufacturer of metal tubing for medical, military, and industrial clients — racked up 11 separate federal hazardous waste violations during a two-day EPA inspection in August 2023.
- The EPA found unlabeled drums of flammable solvent waste, a cracked containment pad sitting under active chemical tanks, and a 2,000-gallon hazardous waste tank that was never inspected daily as required by law.
- Viant skipped mandatory hazardous waste safety training for 19 employees — across two full calendar years — leaving workers unaware of how to handle toxic materials they were touching every day.
- The company operated its entire hazardous waste storage operation without a permit, without interim status, and without a valid exemption — meaning it was running an illegal toxic waste site inside a residential county.
- The EPA fined Viant $170,000 (roughly the annual salary of 2.3 average American workers, or enough to fund 10 low-income students through a full year of community college) — a sum the company agreed to pay to close the case.
The crack in the containment pad under the solvent tanks is documented in Section 6. The workers who never received a single day of hazardous waste training are in The Non-Financial Ledger.
Environmental Accountability
Viant’s Toxic Shortcut
A manufacturer that makes metal tubing for hospitals and the U.S. military let a three-foot crack sit open in the concrete pad holding its chemical solvent tanks — and left the workers breathing the fumes with zero hazardous waste training for two straight years.
Who Is Viant, and What Are They Making?
Viant Collegeville, LLC operates a manufacturing facility at 200 West 7th Street in Collegeville, Pennsylvania — a suburb sitting in Montgomery County, about 25 miles from Philadelphia. The company custom-manufactures small-diameter metal tubing for medical devices, industrial applications, and military and government contracts.
To make that tubing, Viant runs a series of industrial chemical processes: seam-welding, drawing, annealing, and surface treatment. Before the annealing process, the facility flushes and degreases metal parts using two primary solvents: Oxsol (Parachlorobenzotrifluoride) and trichloroethylene, better known as TCE. TCE is a volatile organic compound classified as a known human carcinogen by the EPA. It is also one of the most common groundwater contaminants in the country.
The EPA classifies Viant as a Large Quantity Generator of hazardous waste — the highest-tier designation, meaning the facility produces enough toxic material to trigger the strictest federal oversight rules. Despite that designation, Viant operated its hazardous waste storage area entirely without a permit.
The Scale of the Problem
Viant’s primary hazardous waste streams, according to the EPA inspection, include still bottoms from solvent recovery, solvent-contaminated debris, and non-recoverable waste solvent including used acetone and acid-contaminated solvent batches. These are not trace amounts — these are the industrial byproducts of a large-scale chemical operation running inside a populated Pennsylvania county.
Eleven Ways They Broke the Law
On August 15 and 16, 2023, EPA inspectors from Region 3 walked through the Viant Collegeville facility and documented a cascade of violations spanning every major category of hazardous waste management law. What they found was a facility operating as though the rules simply did not apply to it.
Count 1: Running an Illegal Toxic Waste Site
Federal law is clear: if you store hazardous waste, you need a permit. Viant had none. The company held no permit to operate a hazardous waste storage facility, had no interim status, and the EPA concluded it did not meet the conditions of the generator exemption that would have otherwise covered its operations. Operating without a permit is the foundational violation from which almost everything else follows.
Drums Everywhere, Labels Nowhere
During the inspection, EPA representatives found an extensive pattern of containers holding hazardous waste with no required labels, no accumulation start dates, and no identification of contents. The violations span multiple buildings and areas of the facility. The full list includes:
- One 15-gallon can of Oxsol in the Oxsol Flusher Area of Plant 2 — unlabeled and not marked with contents
- Two 55-gallon hazardous waste drums stored together in the Oxsol Flusher Area — no accumulation start dates
- One 55-gallon drum in Plant 1 containing waste generated from areas outside the room — no accumulation start date
- Two 55-gallon drums in the ID/OD Coating area — listed as “satellite accumulation” but missing required accumulation dates
- Three 55-gallon drums in Plant 1 Degreaser Area — no accumulation start dates; one also contained waste from an adjacent room
- Two 4-liter containers in the Metlab — not labeled as hazardous waste, contents unknown, no accumulation dates
- Three 5-gallon containers in satellite accumulation outside the Nitinol Secondary Processing room — no accumulation start dates
EPA Violations by Category — Viant Collegeville, LLC (August 2023 Inspection)
Count 2: They Couldn’t Even Identify Their Own Waste
Federal hazardous waste law requires that anyone generating solid waste must make a formal determination about whether that waste is hazardous. Viant failed this basic test in multiple areas. Inspectors found a 55-gallon drum in the COE pad printing area that smelled of solvents but was labeled as non-hazardous “Ink Debris.” A horizontal drum in the ID/OD Coating area had resinous material actively leaking from a drum tap into an open, unlabeled tote sitting below it.
The discrepancies in Viant’s own waste shipment records are damning. The waste codes listed on electronic manifests differed from the paper manifests for the same shipments. The facility’s 2019 Biennial Report listed waste codes D001, D006 (cadmium), and D007 (chromium), but the 2021 Biennial Report applied only D001 and D007. The company claims no lead is present, yet D008 (lead) codes appear on some manifests and not others. No laboratory analyses had ever been conducted on the facility’s major waste streams: wastewater treatment sludge and sandblast grit.
Count 3: Lost Paper Trail on Toxic Shipments
When hazardous waste leaves a facility, a signed manifest must follow it through the chain of custody and return to the generator. Viant could not produce signed copies of four manifests from March to July 2023, and filed no exception reports as required by law. The missing manifests included shipments from May 3, May 27, and June 19, 2023. The company only retrieved the signed copies after inspectors showed up and flagged the missing paperwork.
The Non-Financial Ledger: What This Cost the People Inside
Numbers on a penalty notice don’t capture what it means to work alongside carcinogenic solvents for two years without anyone ever telling you what they can do to your body. That is the reality for the workers at Viant Collegeville. The EPA’s inspection found that 19 employees at the facility received neither initial RCRA hazardous waste training nor the annual refresher training required by law for calendar years 2021 and 2022. That is not a paperwork gap. That is a management decision to leave workers uninformed about the hazards surrounding them every single day.
Federal law requires that employees working at hazardous waste facilities complete a training program within six months of being assigned to a position — and that they cannot work in unsupervised roles until that training is complete. The regulation exists because hazardous waste emergencies are time-sensitive. A worker who doesn’t know what chemicals they’re handling cannot respond effectively when a drum ruptures, a tank leaks, or fumes start building. Viant sent 19 people into that environment with no preparation. The EPA found that all 19 employees also failed to complete initial RCRA training at the facility — meaning some of these workers may have never received formal hazardous waste instruction at any point during their employment there.
The failure to train wasn’t the only way management left workers exposed. The EPA observed that three of the eight job descriptions Viant provided made no mention of hazardous waste responsibilities or qualifications whatsoever — despite those positions involving direct contact with toxic materials. The company also failed to maintain a list of which employees were even required to have RCRA training, making accountability impossible to verify from the inside. Workers cannot advocate for their own safety when the paperwork their employer keeps doesn’t acknowledge that hazard exists.
Then there is the cracked containment pad. The EPA documented a three-foot-long crack in the secondary containment pad located directly beneath the working and new solvent tanks. Secondary containment exists for one purpose: to catch hazardous chemicals if the primary container fails, preventing them from reaching the soil, groundwater, and the surrounding community. A three-foot crack in that barrier is not a maintenance issue. It is an open door for TCE — a known carcinogen — to migrate into the ground beneath a Pennsylvania suburb. This is the kind of infrastructure failure that produces contaminated wells and cancer clusters a generation later, long after the company has moved on or restructured.
Legal Receipts: What the Documents Actually Say
These are direct citations and findings from the EPA consent agreement. Read them in their own words.
“At the time of the August 15-16, 2023 Inspection, the EPA observed a 3-foot-long crack in the secondary containment pad where the working and new solvent tanks were located at the Facility.” EPA Consent Agreement, Count 6 — Failure to Maintain the Facility to Prevent a Release
“Respondent did not provide RCRA initial and annual refresher training for 19 employees at the Facility. Specifically: four (4) employees for 2021; eight (8) employees in 2022; and seven (7) employees in 2021 and 2022 at the Facility did not receive annual RCRA training; and all 19 employees did not complete initial RCRA training at the Facility.” EPA Consent Agreement, Count 4 — Failure to Provide RCRA Training
“No laboratory analyses had been conducted of the major waste streams including the Facility’s wastewater treatment sludge and sandblast grit.” EPA Consent Agreement, Count 2 — Failure to Conduct Hazardous Waste Determinations
“One (1) Horizontal drum of a hazardous ingredient was observed in ID/OD Coating area, with resinous material leaking from drum tap into an open and unlabeled tote and can below.” EPA Consent Agreement, Count 2 — Failure to Conduct Hazardous Waste Determinations
“The EPA reserves the right to commence action against any person, including Respondent, in response to any condition which the EPA determines may present an imminent and substantial endangerment to the public health, public welfare, or the environment.” EPA Consent Agreement — Reservation of Rights
“Respondent had failed to conduct and document daily inspections for a 2,000-gallon hazardous waste tank in the Fabrication Building at the Facility. The Respondent stated that the maintenance crew conducted weekly inspections, but documentation provided shows some inspections conducted weekly, and some conducted monthly.” EPA Consent Agreement, Count 8 — Failure to Conduct Daily Hazardous Waste Tank Inspections
Societal Impact: Who Else Gets Hurt
Environmental Degradation
The chemicals at the center of this case are serious. Trichloroethylene (TCE) — one of Viant’s primary degreasers — is a volatile organic compound and a classified human carcinogen. It is one of the most prevalent groundwater contaminants in the United States, infamous for contaminating aquifers near industrial sites for decades after manufacturing stops. The EPA recognized TCE as carcinogenic to humans in 2011. Sites that mismanage TCE waste don’t just face administrative penalties; they can generate Superfund liability that costs communities hundreds of millions of dollars to remediate.
The cracked containment pad documented in this case represents a direct pathway for chemical contamination. Secondary containment systems exist specifically to prevent what happens when primary storage fails — a drum breach, a tank overflow, an equipment failure. With a three-foot crack sitting open beneath active solvent tanks, any spill or leak during normal operations would move directly into the soil beneath the facility. Montgomery County, Pennsylvania sits atop aquifer systems that serve residential communities. The EPA’s own legal reservation clause specifically preserves the right to re-engage Viant if a condition emerges that presents “imminent and substantial endangerment to the public health, public welfare, or the environment.” That language does not appear in settlements where regulators feel confident the problem is fully resolved.
The Oxsol (Parachlorobenzotrifluoride) flushing and degreasing operations generated waste streams that Viant stored in multiple unlabeled, undated drums across at least five separate areas of the facility. Without accurate accumulation dates, there is no enforceable legal pressure on the company to ship these materials off-site within required time windows. Waste that accumulates beyond regulatory limits creates concentrated pools of toxic material that increase the risk of spills, fires, and environmental release.
Public Health
TCE exposure is linked to kidney cancer, non-Hodgkin’s lymphoma, and liver cancer. It also causes neurological damage, reproductive harm, and developmental problems in children exposed in utero. The workers inside Viant’s Collegeville facility who handled TCE stills, collected solvent bottoms, and worked around degreaser tanks were exposed to these risks. Nineteen of those workers spent at least one to two years with no formal training on how to protect themselves, respond to spills, or recognize symptoms of chemical exposure. They did not choose this. They were simply not told.
The contingency plan failures compound the health risk for anyone inside the building. The EPA found that Viant’s emergency plan listed “Incident Commanders” rather than the required “Emergency Coordinators” with updated contact information, and failed to include evacuation diagrams or route maps in the plan document itself. In the event of a fire, explosion, or sudden release of TCE or flammable solvent waste — classified under hazardous waste number D001 — workers at this facility would be operating from an incomplete, potentially outdated emergency response framework. Evacuation diagrams were posted in some areas of the building, but an emergency plan that depends on wall postings rather than a verified, up-to-date official document is a plan designed to fail under pressure.
The 2,000-gallon hazardous waste tank in the Fabrication Building is another public health pressure point. This tank held hazardous materials — and Viant’s own records showed inspections happening weekly and monthly, not the legally required daily inspection. A 2,000-gallon tank leaking hazardous waste undetected for even a few days can cause serious environmental damage. The law requires daily checks because small leaks become large contamination events when nobody is looking.
Economic Inequality
The community most exposed to Viant’s lapses is working-class by definition: the people who take manufacturing jobs, who live near industrial facilities, and who rely on regulatory agencies to enforce the rules that protect them from corporate shortcuts. Those 19 undertrained workers were not executives. They were hourly employees working the floor, handling chemicals their employer categorized on job descriptions as having nothing to do with hazardous materials — even when those jobs clearly did.
The $170,000 penalty ($170,000 — roughly the cost of a modest home in many parts of Pennsylvania, or less than six months of salary for a mid-level corporate executive) resolves the EPA’s civil claims but does nothing for workers who spent two years in a toxic environment without proper safety education. There is no compensation mechanism in this settlement for occupational exposure. There is no medical monitoring requirement. There is no requirement to notify current or former employees that the facility was out of compliance with hazardous waste laws during the period they worked there. The settlement protects the company’s liability. The workers carry their exposure forward with no acknowledgment from the legal process that it happened.
The Cost of a Shortcut
Please visit this link to see the above EPA document: https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/9E61E58C356382A685258D0D006EA80B/$File/Viant%20Collegeville%20LLC_RCRA%20CAFO_Sept%2022%202025_Redacted.pdf
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