EPA v. HANKOOK & COMPANY ES AMERICA CORP.

Case summary

SEPTEMBER 11, 2025 - CONSENT AGREEMENT On March 6, 2024, the EPA and TDEC conducted a hazardous waste compliance evaluation inspection (CEI) at the Facility. The EPA's findings of the CEI were documented in a Report that was emailed to Respondent on June 11, 2024. The inspectors observed that Respondent had not made an accurate hazardous waste determination on the following: a. spent aerosol cans in the Raw Material Warehouse; b. one 55-gallon container affixed with a vacuum to accumulate the dust in the Assembly Area; c. eight 55-gallon unmarked containers storing unknown material on the south side of the building. The inspectors observed three open 55-gallon containers of lead? contaminated Personal Protective Equipment (PPE) hazardous waste in three SAAs around the Facility: The inspectors observed five SAA containers of hazardous waste PPE (D008) that were not marked with the words Hazardous Waste or with an indication of the hazards of their contents. These containers were found in four SAAs around the Facility. The inspectors observed two 55-gallon containers for accumulating hazardous waste PPE in the Wastewater Treatment Area SAA. One of the containers was completely full of hazardous waste, and the other was partially full of hazardous waste. Therefore, the total volume of hazardous waste observed in the SAA exceeded 55 gallons. The inspectors observed hazardous waste contaminated PPE outside of a container on a pallet beside the Wastewater Treatment Area SAA. Respondent did not ensure that the hazardous waste contaminated PPE was placed inside the accumulation container. The inspectors observed six open containers of hazardous waste in five CAAs around the Facility No records of weekly inspections of the CAAs were available for the years 2021, 2023, or 2024, and records of only six weekly inspections were available for the year 2022. The inspectors observed seven containers of hazardous waste that were not marked with the words Hazardous Waste in three CAAs around the Facility The inspectors observed eleven containers of hazardous waste that were not marked with an indication of the hazards of their contents in six CAAs around the Facility. The inspectors observed ten containers of hazardous waste that were not marked with an accumulation start date. These containers were found in five CAAs around the Facility. In a CAA outside on the south side of the WWTP building, the inspectors observed a pallet which held two lead paste sluice gates, covered with caked-on lead paste, that were not inside any container. Respondent did not ensure that hazardous waste was placed inside an accumulation container. The inspectors observed that the list of emergency coordinators in the Facility's contingency plan included personnel who no longer worked at the Facility. The inspectors observed that the Facility's training records showed that Respondent had not conducted any annual reviews of the initially required hazardous waste training for any of the Facility's personnel who were filling a position related to hazardous waste management. The inspectors reviewed hazardous waste manifest records documenting Respondent's shipments of hazardous waste off-site to treatment, storage, or disposal facilities within the United States. Respondent consents to the payment of a civil penalty, which was calculated in accordance with the Act, in the amount of ONE HUNDRED EIGHTY THOUSAND DOLLARS ($180,000.00). Based on Respondent's written certification to the EPA that payment of the entire penalty within thirty (30) days after the Effective Date of this CAFO would result in a financial hardship, the EPA has agreed to allow Respondent to pay the penalty in installments to be completed within six (6) months after the Effective Date.

Defendants (1)

• HANKOOK & COMPANY ES AMERICA CORP.Named in complaintNamed in settlement

Facilities (1)

• HANKOOK & COMPANY ES AMERICA CORP.

  1325 INTERNATIONAL BLVD, CLARKSVILLE, TN, 37042

  Registry ID: 110070801532

Statutes cited

• RCRA 3004 — Hazardous Waste Treatment, Storage, and Disposal Standards
• RCRA 3005 — Permits for Treatment, Storage, or Disposal of Hazardous Waste
• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• HANKOOK & COMPANY ES AMERICA CORP.entered 2025-09-15

  Primary law: RCRA

  Federal penalty: $180,000

Timeline (3 milestones)

• 2025-09-11Complaint Filed/Proposed Order
• 2025-09-15Final Order Issued
• 2025-09-15Enforcement Action Data Entered