EPA v. TNEMEC COMPANY, INC.

Case summary

On January 10, 2022 EPA Region III filed a Consent Agreement and Final Order, simultaneously commencing and concluding an administrative action proceeding against TNEMEC Company, Inc. ( TNEMEC ) located at 2300 Edgewater Avenue Baltimore, MD ( Facility ) for alleged violations of the Resource Conservation and Recovery Act ( RCRA ) and the authorized Code of Maryland Regulations ( COMAR ) discovered after an EPA inspection of the Facility on August 28-29, 2019. RCRA gives EPA the authority to control hazardous waste from the cradle-to-grave. This includes the generation, transportation, treatment, storage and disposal of hazardous waste. To that end, EPA develops regulations, guidance and policies that ensure the safe management and cleanup of solid and hazardous waste, and programs that encourage source reduction and beneficial reuse. TNEMEC manufactures commercial and industrial paint coatings. The violations in the settlement include operation without a hazardous waste permit, failure to make a hazardous waste determination, failure to keep containers of hazardous waste closed, failure to maintain an adequate contingency plan for the Facility, failure to operate in such a way as to minimize the possibility of a release, failure to inspect daily and provide documentation of hazardous waste tank inspections, and failure to conduct initial and provide annual hazardous waste training, failure to conduct monthly monitoring and mark Subpart BB equipment. Region 3 notified Maryland, which had no objections to this action. Per the terms of the Consent Agreement, TNEMEC will pay a civil penalty in the amount of $87,340.00. The Facility is in an EJ sensitive area.

Defendants (1)

• TNEMEC COMPANY, INC.Named in complaintNamed in settlement

Facilities (2)

• TNEMEC COMPANY

  2300 EDGEWATER AVE., BALTIMORE, MD, 21222-4097

  Registry ID: 110000339820

• TNEMEC COMPANY, INC.

  2300 EDGEWATER AVE, BALTIMORE, MD, 21222-4097

  Registry ID: 110000339820

Statutes cited

• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• TNEMEC COMPANY, INC.entered 2022-01-10

  Primary law: RCRA

  Federal penalty: $87,340

Timeline (4 milestones)

• 2022-01-10Final Order Issued
• 2022-01-10Complaint Filed/Proposed Order
• 2022-01-12Enforcement Action Data Entered
• 2022-01-13Enforcement Action Closed