In the fourth quarter (Q4) of 2024, the EPA finalized 215 settlement agreements with companies small and large across the United States. This represents a decrease in enforcement actions—down from 482 penalties issued in Q3. The actions taken resulted in $7,739,116 in fines. Here are some of the highlights.

CAA violations yield biggest fine from EPA

The largest Q4 fine assessed by the EPA was to a natural gas processing and fractionation services company, which must pay $1,900,000 for violations of the Clean Air Act (CAA). Two of the company’s gas plants in New Mexico failed to comply with the New Source Performance Standards (NSPS)Specifically, the plants failed to:

• Operate valves and pressure relief devices with no detectable emissions.
• Monitor components at the facilities at the required monthly, quarterly, or other frequency.
• Repair a valve within 15 days of identification of a leak.
• Timely identify the applicability of the NSPS for process units at the facilities.

According to the New Mexico Environment Department, the gas processing company has been fined in the past for hundreds of air pollution and other environmental violations.
There were additional enforcement actions taken against 25 other entities for CAA violations, with penalties ranging from $800 to $445,362. In all, CAA violations accounted for $3,699,057 in Q4.

FIFRA violations

An industrial wastewater treatment systems company agreed to settle with the EPA to resolve violations of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Allegedly, the Wisconsin company sold or distributed Aqua Dry and Air Relief 3001, two unregistered pesticides the company claimed would kill bacteria, germs, and viruses. As part of the settlement agreement, the company will pay a $546,972 penalty.
The EPA has reached a settlement agreement with a Michigan pond supply company for violating FIFRA regulations. In addition to selling or distributing unregistered pesticides, the company also possessed adulterated or misbranded pesticides. A $162,246 fine has been issued.

RCRA violations bringing six-figure fines

The EPA continues its consistent enforcement for Resource Conservation and Recovery Act (RCRA) violations:

• A Georgia resin manufacturer must complete a Supplemental Environmental Project (SEP) and pay $332,000 in penalties for RCRA violations during a compliance evaluation inspection. The violations include:
• Failing to make an accurate hazardous waste determination for the acetone-contaminated wastewater accumulating in the secondary containment area;
• Shipping the wastewater from the secondary containment area as nonhazardous waste;
• Possessing an improperly sealed 55-gallon container of hazardous waste spent filters labeled as “Hazardous Waste” but without identifying the hazards of the container’s contents;
• Not conducting weekly inspections of hazardous waste in the central accumulation area; and
• Failing to update its facility-specific contingency plan.
• Two plastic packaging companies were fined $182,879 after EPA inspections at their Kansas facilities. Approximately $710,000 will also be spent for upgrades to resolve RCRA violations. According to the EPA, the companies violated federal law by:
• Operating a hazardous treatment, storage, or disposal facility without a permit,
• Failing to comply with universal waste and used oil management regulations,
• Failing to conduct hazardous waste determinations, and
• Failing to provide required notification to the state about changes in company operations.
• The EPA reached a $150,356 settlement with a Wisconsin tubing and pipe manufacturer for RCRA violations, including failure to:
• Properly store hazardous waste on-site with a hazardous waste storage license.
• Make and complete hazardous waste determinations.
• Mark accumulation start dates visibly and accurately on containers.
• Label and close satellite accumulation containers.
• Provide training to employees whose job duties include hazardous waste management.
• Properly manage universal waste lamps and batteries.

Emphasizing clean water

The EPA cited 24 different entities for violations of the Clean Water Act (CWA), including oil and paper producing facilities, for inadequate Spill Prevention, Control, and Countermeasure (SPCC) plans, as well as a cattle and timber company for dredge and fill material permit violations. The fines totaled $724,270 and ranged from $675 to $177,759.

TSCA violations

A South Carolina chemical plant was fined $315,000 for violating the Toxic Substances Control Act (TSCA). The EPA outlined two major violations: failing to submit a premanufacture notice (PMN) at least 90 days before importing a new chemical substance and submitting incorrect certifications that its imported chemicals were in compliance with TSCA.
A bromine and lithium production company in North Carolina agreed to pay $212,480 to resolve TSCA violations. After reviewing records, the EPA determined that the company violated TSCA by failing to submit a Chemical Data Reporting (CDR) report for imported chemicals and failing to report volumes of the imported chemicals to two significant figures of accuracy.