EPA v. WARNER GRAHAM LLLP

Case summary

SETTLING VIOLATIONS OF RCRA SUBTITLE C THAT EPA INSPECTORS OBSERVED DURING AN INSPECTION OF THE COMPANY'S FACILITY IN COCKEYSVILLE, MD. DURING THE INSPECTIONS, AND THROUGH A SUBSEQUENT INFORMATION REQUEST, EPA INSPECTORS OBSERVED THAT THE FACILITY: (1) OPERATED A HAZARDOUS WASTE STORAGE FACILITY WITHOUT A PERMIT OR INTERIM STATUS, (2) FAILED TO RETAIN TSD SIGNED MANIFESTS OR SUBMIT EXCEPTION REPORT, (3) FAILED TO SUBMIT BIENNIAL REPORT, (4) FAILED TO PROVIDE INITIAL AND ANNUAL HAZARDOUS WASTE REFRESHER TRAINING, (5) FAILED TO PREPARE AND MAINTAIN HAZARDOUS WASTE TRAINING AND PERSONNEL RECORDS, (6) FAILED TO MAINTAIN ADEQUATE CONTINGENCY PLAN, (7) FAILED TO CONDUCT AND DOCUMENT DAILY HAZARDOUS WASTE TANK INSPECTIONS, (8) FAILED TO MAINTAIN CERTIFIED INTEGRITY ASSESSMENT OF NEW HAZADOUS WASTE TANK, (9) FAILED TO MAINTAIN ADEQUATE SECONDARY CONTAINMENT FOR HAZARDOUS WASTE TANK, (10) FAILED TO DETERMINE WHETHER EQUIPMENT CONTAINS OR CONTACTS A HAZARDOUS WASTE WITH 10% OR MORE ORGANIC CONCENTRATION, (11) FAILED TO MARK EACH PIECE OF EQUIPMENT, (12) FAILED TO INSPECT WEEKLY AND MONITOR MONTHLY PUMPS IN LIGHT LIQUID SERVICE, (13) FAILED TO MONITOR MONTHLY VALVES IN GAS/VAPOR SERVICE OR IN LIGHT LIQUID SERVICE, (14) FAILED TO MAINTAIN RECORDS OF EQUIPMENT, (15) FAILED TO DETERMINE MAXIMUM ORGANIC VAPOR PRESSURE FOR HAZARDOUS WASTE TANK, (16) FAILED TO INSPECT AND MONITOR EMISSION CONTROL EQUIPMENT, (17) FAILED TO MAINTAIN RECORDS FOR TANK. THE CONSENT AGREEMENT AND FINAL ORDER INITIATE AND CONCLUDE THIS ACTION.

Defendants (1)

• WARNER GRAHAM LLLP (SB)Named in complaintNamed in settlement

Facilities (2)

• WARNER GRAHAM LLLP

  160 CHURCH LANE, COCKEYSVILLE, MD, 21030-4921

  Registry ID: 110001276716

• WARNER GRAHAM LLLP

  160 CHURCH LANE, COCKEYSVILLE, MD, 21030-4921

  Registry ID: 110001276716

Statutes cited

• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• WARNER GRAHAM LLLPentered 2013-09-24

  Primary law: RCRA

  Federal penalty: $80,650 · SEP: $24,550

Timeline (3 milestones)

• 2013-09-24Complaint Filed/Proposed Order
• 2013-09-24Final Order Issued
• 2013-10-22Enforcement Action Data Entered