EPA v. TRELLEBORG NEW HAVEN

Case summary

On December 4, 2023, EPA sent a stipulated penalty demand for $51,000 to Trelleborg Coated Systems US, Inc. for violations of an administrative Clean Air Act Consent Agreement and Final Order (CAFO) that EPA had filed in March of 2023. Trelleborg paid the penalty on December 15, 2023. Until October 4, 2023, Trelleborg operated an equipment coating facility in New Haven, Connecticut that primarily performed urethane coating and laminating processes on various fabrics to achieve water and chemical repellant and flame-retardant properties. The CAFO alleged that the company violated its Clean Air Act New Source Review Permit to Construct and Operate a Stationary Source. Under the CAFO, the company had agreed to pay a penalty and comply with conditions in the CAFO, including maintaining operating logs for the enclosures, and paying stipulated penalties if it failed to come into compliance or permanently shut down all its coating operations at its New Haven facility by July 1, 2023. Trelleborg was late in shutting down its coating operations, thereby triggering the stipulated penalty provisions of the CAFO. On March 23, 2023, the U.S. Environmental Protection Agency (EPA) filed an administrative settlement concerning Trelleborg Coated Systems US, Inc. (Trelleborg). Trelleborg has a manufacturing facility in New Haven, Connecticut that primarily performs urethane coating and laminating processes on various fabrics to achieve water and chemical repellant and flame-retardant properties for fabrics used for products such as escape slides for aircrafts, blood pressure cuffs, mattresses, and protective clothing. EPA is alleging that Trelleborg violated its Clean Air Act New Source Review Permit to Construct and Operate a Stationary Source, which concerns the operation of six coating lines and two laminating lines, the associated capture systems, and the control system. The company has agreed to pay a penalty of $305,305 and has agreed to conditions in the CAFO, including maintaining operating logs for the enclosures, and paying stipulated penalties if it fails to come into compliance or permanently shut down all its coating operations at its New Haven facility by July 1, 2023. Trelleborg is located in an area that is identified as having seven or more environmental justice indicators above the 80th percentile in the United States.

Defendants (1)

• Trelleborg Coated Systems US, Inc.Named in complaintNamed in settlement

Facilities (1)

• URETEK, INCORPORATED

  30 LENOX STREET, NEW HAVEN, CT, 06513

  Registry ID: 110000316854

Statutes cited

• CAA 110 — Implementation Plan for National Primary and Secondary Ambient Air Quality Standards

Enforcement conclusions (1)

• TRELLEBORG NEW HAVENentered 2023-03-23

  Primary law: CAA

  Federal penalty: $305,305

Timeline (3 milestones)

• 2023-03-23Final Order Issued
• 2023-03-23Complaint Filed/Proposed Order
• 2023-03-29Enforcement Action Data Entered