EPA v. Samvardhana Motherson Reflectec Automotive Systems

Case summary

Region 5 files Consent Agreement and Final Order with SMR Automotive Systems of Marysville, Michigan to resolve alleged violations of RCRA. The enforcement action requires the facility to conduct regular leak detection monitoring on equipment that transfers hazardous waste solvents. The facility has purchased leak detection and monitoring equipment, trained employees on its proper use, and has cataloged all transfer equipment on site. The enforcement action will also ensure that facility employees are adequately and regularly trained in general hazardous waste management procedures. On August 17, 2017, EPA filed a Consent Agreement and Final Order (CAFO) with Samvardhana Motherson Reflectec (SMR) Automotive Systems, commencing and concluding an administrative action under the Resource Conservation and Recovery Act (RCRA). SMR is a manufacturer, assembler and painter of interior and exterior automotive mirrors and related components. The CAFO alleges that SMR violated RCRA as noted during an inspection on July 7, 2015. The allegations include: 1) failure to label and manage containers storing hazardous waste, 2) failure to provide hazardous waste management training to company personnel for several consecutive years, 3) possessing an inadequate hazardous waste contingency plan, 4) failure to conduct monthly leak detection and monitoring for Subpart BB hazardous waste transfer equipment, 5) failure to maintain records related to Subpart BB equipment, and 6) failure to adequately control emissions from Subpart CC hazardous waste containers. SMR has agreed to pay a civil penalty of $197,000. The CAFO does not require specific injunctive relief because of the complying actions taken by SMR since the inspection and Notice of Violation. SMR has demonstrated that it is now in compliance with all applicable RCRA regulations.

Defendants (1)

• Samvardhana Motherson Reflectec Automotive SystemsNamed in complaintNamed in settlement

Facilities (1)

• SAMVARDHANA MOTHERSON REFLECTIC

  1875 BUSHA HIGHWAY, MARYSVILLE, MI, 48040-1892

  Registry ID: 110040497101

Statutes cited

• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• Samvardhana Motherson Reflectec Automotive Systemsentered 2017-08-17

  Primary law: RCRA

  Federal penalty: $197,000

Timeline (3 milestones)

• 2017-08-17Complaint Filed/Proposed Order
• 2017-08-17Final Order Issued
• 2017-08-18Enforcement Action Data Entered