EPA v. ZKW Trading Default Complaint

Case summary

On January 4, 2010, the EPA issued an administrative complaint against ZKW Trading Corp of Monterey Park, Calif. seeking penalties of up to $37,500 per day for ZKW’s failure to comply with a final order. The order was part of a complaint issued by EPA in September 2009, which alleged that ZKW failed to notify the EPA of export of cathode ray tubes (CRTs), a violation of RCRA. The order required ZKW to take possession of and manage appropriately about 65,000 pounds of electronic waste. ZKW had shipped the electronic waste, including CRTs, to Hong Kong as “plastic scrap.” The shipment was rejected in Hong Kong and returned to the Port of Long Beach. CRTs contain lead and other heavy metals at high enough concentrations to be considered hazardous waste. Regulations took effect in January 2007 requiring exporters shipping broken or unbroken CRTs to another country for recycling to notify the EPA and receive written consent from the receiving country before shipments can be made. Penalty is $37,500/day from October 9, 2009 until ZKW Trading complies with original Order. Robert Pang has left the country (he resides in Hong Kong) and will most likely not ever pay the penalty.

Defendants (1)

• Robert PangNamed in complaint

Facilities (1)

• ZKW TRADING CORP.

  218 W. GARVEY AVE., STE I, MONTEREY PARK, CA, 91754

  Registry ID: 110040055935

Statutes cited

• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Timeline (2 milestones)

• 2009-12-31Complaint Filed/Proposed Order
• 2010-02-17Enforcement Action Data Entered