EPA v. Image Set Inc

Case summary

On January 21st, 2020 EPA Region 6 issued an Administrative Compliance order ACOC on Consent under its authority pursuant to RCRA to Image SET located in 6611 Portwest Drive, Suite 190 Houston, TX 77024(the ?Facility?). The ACOC was issued in response to violations of: 1) Failure to make hazardous waste determination 2)Failure to meet the manifest requirement . The ACOC requires Image Set to certify that it has assessed all of its solid waste streams to determine the accurate waste codes and has developed and implemented Standard Operating Procedures (?SOP?) to ensure that Image Set is operating in compliance with RCRA and the regulations promulgated thereunder, including, but not limited to, procedures for: (a) making hazardous waste determinations; (b) managing hazardous wastes; (c) reporting, transporting, and disposing of hazardous waste; (d) preparing the manifests; and (e) meeting the requirements of the land disposal restrictions; B. Certify that it has accurately and adequately complied with its RCRA Section 3010 Notification; and C. Provide with its certification, a copy of SOPs. Image Set must respond to EPA Region 6 by 30 calendar days from the ACOC is filed.

Defendants (1)

• Image SetNamed in complaintNamed in settlement

Facilities (1)

• IMAGE SET

  6611 PORTWEST DRIVE, SUITE 190, CITY OF HOUSTON, TX, 77024

  Registry ID: 110070703557

Statutes cited

• RCRA 3008A — Compliance Order: Injunctive & Penalty
• RCRA 3010 — Notification of Hazardous Waste Activity
• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• Image Set Incentered 2020-01-21

  Primary law: RCRA

Timeline (5 milestones)

• 2020-01-21Complaint Filed/Proposed Order
• 2020-01-21Final Order Issued
• 2020-03-06Compliance Achieved
• 2020-03-17Enforcement Action Data Entered
• 2021-07-06Enforcement Action Closed