EPA v. SPRAY PRODUCTS CORPORATION

Case summary

SPRAY PRODUCTS CORPORATION VIOLATED 25 PA CODE SECTION 270a.1, WHICH INCORPORATED BY REFERENCE 40 C.F.R. SECTION 270.1(b), AND SECTION 3005(a) OF RCRA, 42 U.S.C. SECTION 6925(a), BY OPERATING A HAZARDOUS WASTE STORAGE FACILITY WITHOUT A PERMIT OR INTERIM STATUS OF VALID EXEMPTION. SPRAY PRODUCTS CORPORATION VIOLATED 25 PA CODE SECTION 262a.1, WHICH INCORPORATES BY REFERENCE 40 C.F.R. SECTION 262(a)(2), WITH EXCEPTIONS NOT RELEVANT HERE, BY FAILING TO FILE EXCEPTION REPORTS WITH THE PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION WHEN SPRAY PRODUCTS CORPORATION DID NOT RECEIVE COPIES OF THE MANIFEST FOR HAZARDOUS WASTE SHIPPED FOR DISPOSAL FROM ITS FACILITY WITH THE HANDWRITTEN SIGNATURE OF THE OWNER OR OPERATOR OF THE DESIGNATED DISPOSAL FACILITY WITH 45 DAYS OF THE DATE AND THE WASTES WERE ACCEPTED BY THE INNITIAL TRANSPORTER. SPRAY PRODUCTS CORPORATION VIOLATED 25 PA CODE 264a.1, WHICH INCORPORATES BY REFERENCE 40 C.F.R. SECTION 264.16(d) BY FAILING TO DOCUMENT THE JOB TITLE OF EACH POSITION AT THE FACILITY RELATED TO HAZARDOUS WASTE MANAGEMENT, AND THE NAME OF THE EMPLOYEE FILLING EACH SUCH JOB AS REQUIRED BY 25 PA CODE 264a.1, WHICH INCORPORATES BY REFERNCE 40 C.F.R. SECTION 264.16(d). SPRAY PRODUCTS CORPORATION VIOLATED 25 PA CODE SECTION 264a.1, WHICH INCORPORATES BY REFERENCE 40 C.F.R. SECTION 264.54(d), BY FAILING TO AMEND THE FACILITY CONTINGENCY PLAN. SPRAY PRODUCTS CORPORATION VIOLATED 25 PA CODE SECTION 266b.1, WHICH INCORPORATES BY REFERENCE 40 C.F.R. SECTION 273.13(d)(1), 14(e), AND 15, BY FAILING TO KEEP CONTAINERS OF UNIVERSAL WASTE LAMPS AT THE FACILITY CLOSED, FAILING TO LABEL CONTAINERS OF UNIVERSAL WASTE LAMPS AT THE FACILITY AND FAILING TO DEMONSTRATE THE LENGTH OF TIME THAT UNIVERSAL WASTE LAMPS HAD BEEN ACCUMULATING AT THE FACILITY.

Defendants (1)

• SPRAY PRODUCTS CORPORATION (SB)Named in complaintNamed in settlement

Facilities (2)

• SPRAY PRODUCTS CORPORATION

  1323 CONSHOHOCKEN RD., PLYMOUTH MEETING, PA, 19462

  Registry ID: 110000337519

• SPRAY PRODUCTS CORPORATION

  1323 CONSHOHOCKEN RD., PLYMOUTH MEETING, PA, 19462

  Registry ID: 110000337519

Statutes cited

• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• SPRAY PRODUCTS CORPORATIONentered 2013-02-07

  Primary law: RCRA

  Federal penalty: $25,000

Timeline (3 milestones)

• 2013-02-07Final Order Issued
• 2013-02-07Complaint Filed/Proposed Order
• 2013-02-14Enforcement Action Data Entered