The United States Environmental Protection Agency (“EPA”) and C-P Flexible Packaging (“C-P”) entered into a September 30th Consent Agreement (“CA”) addressing alleged violations of the Pennsylvania regulations addressing hazardous waste. See Docket Number. RCRA-03-2021-0091.
The CA provides that C-P operates a manufacturing facility in Bristol, Pennsylvania (“Facility”).
EPA is stated to have conducted a Resource Conservation and Recovery Act (“RCRA”) Compliance Evaluation Inspection (“CEI”) of the Facility on January 29-30, 2020. Hazardous waste generated by the Facility identified in the CA are stated to have been in “storage” in containers and tanks.
The Facility is stated to generate waste solvent which is a hazardous waste (D001) within the meaning of 25 Pa. Code § 261a.1. The hazardous nature of the waste solvent is that it has the characteristic ignitability.
The CA identifies these alleged violations:
- Without a Permit or Interim Status, a treatment, storage, or disposal facility can be operated
- Failure to make a hazardous waste determination
- Failing to provide RCRA training
- Failure to list emergency equipment in the Facility Contingency plan
- Failure to include an Evacuation Plan in Facility Contingency Plans
- Failure to properly label universal waste
The CA imposes a civil penalty amounting to $19,550.
You can download a copy of the CA Here.