EPA v. TRADEBE TREATMENT AND RECYCLING OF TENNESSEE, LLC

Case summary

5/17/16 - CONSENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $2,400, DUE WITHIN 30 DAYS. ALLEGATIONS: RESPONDENT IS A PRIMARY EXPORTER OF HAZ WASTE. RESPONDENT EXPORTS HAZ WASTE THAT EXHIBIT THE CHARACTERISTICS OF IGNITABILITY (D001), CORROSIVITY (D002), REACTIVITY (D003), AND TOXICITY (INCLUDING BUT NOT LIMITED TO D006 AND D011 WASTES), AS WELL AS LISTED HAZ WASTES, INCLUDING BUT NOT LIMITED TO F006 AND U134 WASTES. ON OR ABOUT JULY 23, 2012, EPA HQ SENT EPA REGION 4 A REFERRAL LISTING CERTAIN DEFICIENCIES IN ANNUAL REPORTING AND MANIFESTING OF RESPONDENT'S EXPORTED WASTE. ON FEB 3, 2016, AFTER BEING CONTACTED BY R4, RESPONDENT SENT R4 INFO REGARDING RESPONDENT'S EXPORT REPORTS FOR 2011, 2012, 2013, AND 2014. BASED ON A REVIEW OF THE INFO, R4 DETERMINED THAT RESPONDENT HAD EITHER FAILED TO REPORT OR UNDERREPORTED THE VOLUME OF HAZ WASTES IN EACH OF ITS ANNUAL REPORTS FOR 2011, 2012, 2013 AND 2014. EPA THEREFORE ALLEGES RESPONDENT VIOLATED TENN. COMP. R. & REGS. 0400-12-01-.03(7)(g) (40 CFR 262.56(a)) FOR FAILING TO FILE AN ACCURATE ANNUAL REPORT ON THE TYPES AND QUANTITIES OF HAZ WASTE EXPORTED FOR 2011, 2012, 2013 AND 2014.

Defendants (1)

• TRADEBE TREATMENT AND RECYCLING OF TENNESSEE, LLCNamed in complaintNamed in settlement

Facilities (2)

• TRADEBE TREATMENT & RECYCLING OF TENNESSEE LLC

  5485 VICTORY LN, MILLINGTON, TN, 38053

  Registry ID: 110000618911

• TRADEBE TREATMENT & RECYCLING OF TENNESSEE LLC

  5485 VICTORY LN, MILLINGTON, TN, 38053

  Registry ID: 110000618911

Statutes cited

• RCRA 3005 — Permits for Treatment, Storage, or Disposal of Hazardous Waste
• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• TRADEBE TREATMENT AND RECYCLING OF TENNESSEE, LLCentered 2016-05-17

  Primary law: RCRA

  Federal penalty: $2,400

Timeline (4 milestones)

• 2016-05-17Complaint Filed/Proposed Order
• 2016-05-17Final Order Issued
• 2016-06-09Enforcement Action Data Entered
• 2017-01-05Enforcement Action Closed