EPA v. UNIFORMED SERVICES UNIVERSITY OF HEALTH SCIENCES

Case summary

On June 7, 2024 EPA Region 3 filed a Consent Agreement and Final Order, simultaneously commencing and concluding an administrative action proceeding against the Uniform Services University of the Health Sciences. ( USUHS ) located at 4301 Jones Bridge Road, Bethesda, MD 20814 ( Facilit ) for alleged violations of the Resource Conservation and Recovery Act ( RCRA ) and the authorized Code of Maryland Regulations ( COMAR ) discovered after a tip/complaint prompted an EPA inspection of the Facility on December 14-15, 2021. USUHS is a health science university and professional school of the U.S. federal government. The primary mission of the school is to prepare graduates for service to the U.S. at home and abroad as uniformed health professionals, scientists and leaders; by conducting cutting-edge, military-relevant research; by leading the Military Health System in key functional and intellectual areas; and by providing operational support to units around the world. The violations in the settlement include operation without a hazardous waste permit, failure to make a hazardous waste determination, failure to annually train laboratory personnel, failure to maintain an adequate contingency plan for the Facility, failure to mark containers of satellite waste as hazardous waste, failure to label universal waste containers properly; and failure to describe hazardous waste duties in job description. Region 3 notified Maryland, which had no objections to this action. Per the terms of the Consent Agreement, USUHS will pay a civil penalty in the amount of $144,638.00. The Facility is not in an EJ sensitive area.

Defendants (1)

• UNIFORMED SERVICES UNIVERSITY OF HEALTH SCIENCESNamed in complaintNamed in settlement

Facilities (2)

• UNIFORMED SERVICE UNIVERSITY OF HEALTH SCIENCES/CNRM

  4301 JONES BRIDGE RD, BETHESDA, MD, 20814

  Registry ID: 110045545576

• UNIFORMED SERVICES UNIVERSITY OF HEALTH SCIENCES

  4301 JONES BRIDGE RD, BETHESDA, MD, 20814

  Registry ID: 110045545576

Statutes cited

• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• UNIFORMED SERVICES UNIVERSITY OF HEALTH SCIENCESentered 2024-06-07

  Primary law: RCRA

  Federal penalty: $144,638

Timeline (4 milestones)

• 2024-06-07Final Order Issued
• 2024-06-07Complaint Filed/Proposed Order
• 2024-06-13Enforcement Action Data Entered
• 2024-06-21Enforcement Action Closed