EPA v. Aura Cacia a Division of Frontier Distribution RCRA 3008A AO For Comp And/Or Penalty - Subtitle C Ex

Case summary

Aura manufactures skin products and aromatherapy products by purchasing essential oils in bulk, adding fragrances to the oils, and bottling finished products into smaller containers on the south side of Urbana, Iowa, since 1993. The facility currently employs approximately 30 full time personnel. When fragrance changes are needed, the facility conducts a cleaning process that generates water/oil and waste ethanol hazardous streams that are collected separately and are managed as hazardous waste. During the inspection, the EPA found that the facility failed to properly label a container in satellite accumulation, failed to maintain a written description of the type and amount of both introductory and continuing training, and failed to dispose of hazardous waste within 90-days of the beginning date of storage. (b) Sensitive Comments not for Public Distribution: The specific three violations are: 1. 40 CFR 262.15(a)(5) requires a generator must mark or label its container with the words ?Hazardous Waste? and an indication of the hazards of the contents. As a result of review of the inspection report, it was determined that the facility did not label one container of approximately 15 gallons of hazardous waste stored in a Satellite accumulation container with the words ?Hazardous Waste,? nor provide an indication of the nature of the hazard. During the CEI, employees of Aura affixed labeling with the words ?Hazardous Waste? and indication of the nature of the hazard to the SAC. 2. 40 CFR 262.17(a)(7)(iv)(C) requires a large quantity generator maintain a written description of the type and amount of both introductory and continuing training that will be given to each person filling a position listed under paragraph (a)(7)(iv)(A) at the facility. As a result of review of the inspection report, it was determined that the written job descriptions failed to include a description of the type and amount of introductory and continuing training. No documentation of compliance has been received. Injunctive relief will be sought to address this violation. 3. 40 CFR 262.17(a) requires as a condition for exemption for a large quantity generator that accumulates hazardous waste is that the large quantity generator accumulates hazardous waste on site for no more than 90 days. The facility made hazardous waste determinations after receiving a Eurofins analytical report on October 31, 2022. They received their EPA ID number on February 8, 2023, and initiated the first shipment of accumulated waste on June 7, 2023. Based on these dates, it appears that Aura accumulated hazardous waste beyond 90 days without a RCRA permit, as prohibited by Section 3005 of RCRA. 29 days beyond 90 days if using the starting date of when the EPA ID was issued February 8, 2023. 130 days beyond 90 days if using the starting date of when the results were received, October 31, 2022. This violation is closed due to the disposal of the hazardous waste.

Defendants (1)

• Aura Cacia a Division of Frontier DistributionNamed in complaintNamed in settlement

Facilities (1)

• AURA CACIA A DIVISION OF FRONTIER DISTRIBUTION LLC

  5398 31ST AVE, URBANA, IA, 52345

  Registry ID: 110043870102

Statutes cited

• RCRA 3008A — Compliance Order: Injunctive & Penalty

Enforcement conclusions (1)

• Aura Cacia a Division of Frontier Distribution RCRA 3008A AO For Comp And/Or Penalty - Subtitle C Exentered 2025-04-17

  Primary law: RCRA

  Federal penalty: $3,750

Timeline (4 milestones)

• 2025-04-17Complaint Filed/Proposed Order
• 2025-04-17Final Order Issued
• 2025-04-18Enforcement Action Data Entered
• 2025-05-09Enforcement Action Closed