EPA v. BRENNER AEROSTRUCTURES, LLC

Case summary

1. From at least May 8, 2013 until October 19, 2016, Respondent violated 25 Pa. Code 270a.1, which incorporates by reference 40 C.F.R.? 270.l(b), and Section 3005(a) of RCRA, 42 U.S.C. 6925(a), by operating a hazardous waste storage facility without a permit, interim status or a valid exemption to the permit requirement. 2. On January 19, 2015 and September 21, 2016, Respondent violated 25 Pa. Code 262a.10, which incorporates by reference 40 C.F.R. 262.11, by failing to conduct hazardous waste determinations on solid waste generated at the Facility. 3. From March 1, 2014 to December 16, 2016, Brenner Aerostructures violated 25 Pa. Code 262a.41 by failing to prepare and submit a copy of a Biennial Report to the Director of PADEP for reporting year 2013. 4. On September 21, 2016, Respondent violated 25 Pa. Code 264a.1, which incorporates by reference 40 C.F.R. 264.173( a), by failing to keep containers storing hazardous waste closed during storage, except when it is necessary to add or remove waste. 5. Respondent violated 25 Pa. Code 264a.1, which incorporates by reference 40 C.F.R. 264.16(d)(l-3), by failing to maintain documents at the Facility for: (1) the job title for each position at the Facility related to hazardous waste management, and the name of the employee filling each such job; (2) a written job description, for each such position; and, (3) a written description of the type and amount of training required. 6. From at least January 1, 2014 Respondent violated 25 Pa. Code 264a. 1, which incorporates by reference 40 C.F.R. 264.16(c) by failing to provide annual RCRA refresher training to Facility personnel.

Defendants (1)

• BRENNER AEROSTRUCTURES, LLCNamed in complaintNamed in settlement

Facilities (2)

• BRENNER AEROSTRUCTURES, LLC

  450 WINKS LANE, SUITE 3, BENSALEM, PA, 19020-5932

  Registry ID: 110038509290

• BRENNER AEROSTRUCTURES, LLC

  450 WINKS LANE, SUITE 3, BENSALEM, PA, 19020-5932

  Registry ID: 110038509290

Statutes cited

• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• BRENNER AEROSTRUCTURES, LLCentered 2018-04-10

  Primary law: RCRA

  Federal penalty: $32,232

Timeline (4 milestones)

• 2018-04-10Final Order Issued
• 2018-04-10Complaint Filed/Proposed Order
• 2018-04-11Enforcement Action Data Entered
• 2018-05-04Enforcement Action Closed