EPA v. TDC, L.L.C.

Case summary

On August 22, 2017, EPA Region 6 issued a Consent Agreement and Final Order (CAFO) under its authority pursuant to the Resource Conservation and Recovery Act (RCRA) to TDC, LLC in Westlake, Texas. Data from a Texas treatment, storage, and disposal facility indicated discrepancies between TDC?s designated status as conditionally exempt and actual shipments as a large quantity generator (LQG) subject to hazardous waste generator requirements. The State participated in training on the data mining methodology. The Region notified the State of the potential violations and our intention to investigate and pursue enforcement before notifying the company by letter in December 2016. The CAFO addresses violations including failure to provide notification of hazardous waste activities, failure to operate within the stated generator status and meet the attendant requirements of a large quantity generator. The CAFO also requires TDC to certify and document compliance with the applicable hazardous waste generator requirements and imposes a penalty of $33,990.

Defendants (1)

• TDC, L.L.C.Named in complaintNamed in settlement

Facilities (4)

• TDC LLC - WESTLAKE PLANT

  200 TRUSDALE ROAD, WESTLAKE, LA, 70669

  Registry ID: 110009583502

• TDC LLC - WESTLAKE PLANT

  200 TRUSDALE ROAD, WESTLAKE, LA, 70669

  Registry ID: 110009583502

• TDC LLC - WESTLAKE PLANT

  200 TRUSDALE ROAD, WESTLAKE, LA, 70669

  Registry ID: 110009583502

• TDC LLC - WESTLAKE PLANT

  200 TRUSDALE ROAD, WESTLAKE, LA, 70669

  Registry ID: 110009583502

Statutes cited

• RCRA 3010 — Notification of Hazardous Waste Activity
• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• TDC, L.L.C.entered 2017-08-24

  Primary law: RCRA

  Federal penalty: $33,990

Timeline (4 milestones)

• 2017-08-24Final Order Issued
• 2017-08-24Complaint Filed/Proposed Order
• 2017-08-29Enforcement Action Data Entered
• 2018-02-16Enforcement Action Closed