Container Reconditioning Company Fined $1.6M in CAA and RCRA Violations

The United States and State of Wisconsin announced a settlement with Container Life Cycle Management LLC (CLCM) that addresses Clean Air Act (CAA) and Resource Conservation and Recovery Act (RCRA) violations at the company’s container reconditioning facilities in the Milwaukee, Wisconsin, area. The company will pay a $1.6 million civil penalty to be split evenly between the United States and the State.

In a complaint filed with the proposed settlement, the United States alleged violations of the CAA, for failure to control emissions of volatile organic compounds as required by the EPA-approved Wisconsin state implementation plan. The complaint also alleges RCRA violations related to storage and handling of hazardous waste at company facilities.

Highlights of the settlement include:

1. The company has installed and must continuously operate a regenerative thermal oxidizer to control air emissions of volatile organic compounds. The company will also construct additional emissions capture systems within the facility and conduct performance testing.
2. The company must install and continuously operate a new digital data recorder to record the temperature of the drum reclamation furnace afterburner. The company must maintain the afterburner temperature at or above 1,650 degrees and conduct performance testing.
3. The company must implement a container management plan, or CMP, for a two-year period established by the consent decree. The CMP provides for storage of heavy and non-empty containers in RCRA-compliant hazardous waste storage areas. Certain reporting requirements continue beyond the initial two-year period.

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