EPA v. GENERAL DYNAMICS - OTS INC

Case summary

On November 25, 2013, outside counsel for GD-OTS contacted Region 1 via telephone regarding 14 electrical transformers and 56 associated capacitors in use at its manufacturing facility in Saco, Maine. All of the transformers and capacitors contained PCBs. GD-OTS was in the process of developing a repowering plan for the facility that included the decommissioning and disposal of all the PCB transformers and capacitors. In reviewing its records regarding the transformers and capacitors, GD-OTS identified potential violations of certain requirements of the PCB regulations. Among other things, GD-OTS found (1) no documentation that its transformers had been registered with EPA by December 28, 1998 (as required by 40 C.F.R. section 761.30(a)(1)(vi)(A); and (2) no annual records or written annual documents logs (as required by 40. C.F.R. 761.180(a). GD-OTS documented these violations in two letters to Region 1, dated November 25, 2013, and January 28, 2014. As a result of the self-disclosure letter, Region 1 has determined that (1) GD-OTS was not authorized to use the 14 PCB transformers since it had acquired the facility in 2000; and (2) GD-TS had failed to keep annual records or written annual document logs for the transformers. GD-OTS has agreed to pay a $8,500 penalty to settle the alleged violations.

Defendants (1)

• GENERAL DYNAMICS - OTS INCNamed in complaintNamed in settlement

Facilities (2)

• GENERAL DYNAMICS - OTS, INC

  291 NORTH STREET, SACO, ME, 01886

  Registry ID: 110000314268

• GENERAL DYNAMICS - OTS, INC

  291 NORTH STREET, SACO, ME, 01886

  Registry ID: 110000314268

Statutes cited

• TSCA 6-PCBS — PCBS

Enforcement conclusions (1)

• GENERAL DYNAMICS - OTS INCentered 2016-07-08

  Primary law: TSCA

  Federal penalty: $8,500

Timeline (3 milestones)

• 2016-06-23Enforcement Action Data Entered
• 2016-07-08Complaint Filed/Proposed Order
• 2016-07-08Final Order Issued