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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 No. 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 waste solvent is stated to be hazardous because it exhibits the characteristic of ignitability.
The CA identifies the following alleged violations:
- Operating a Treatment, Storage, and Disposal Facility without a Permit or Interim Status
- Failure to Make a Hazardous Waste Determination
- Failure to Provide RCRA Training
- Failure to List Emergency Equipment in the Facility Contingency Plan
- Failure to Include Evacuation Plan in the Facility Contingency Plan
- Failure to Properly Label Universal Waste
The CA assesses a civil penalty of $19,550.
A copy of the CA can be downloaded here.
