On November 14, 2012, Region 5 filed a Consent Agreement and Final Order (CAFO) under 40 C.F.R. Part 22 commencing and concluding an administrative action against Bradley Technologies, Inc. and Bradley Adhesive Applications, Inc.(jointly d/b/a Bradley Group of Companies) (ÂBradleyÂ). Bradley owns and operates an Illinois facility that applies adhesives and sealants to fasteners or castings. EPA alleged that Bradley violated the conditions for an exemption from the Resource Conservation and Recovery Act (RCRA) requirement to obtain a permit for the storage, treatment or disposal of hazardous waste when it, inter alia, failed to label and date hazardous waste containers, failed to train hazardous waste management personnel, and failed to have a contingency plan. Additionally, EPA alleged that Bradley failed to make hazardous waste determinations; failed to submit annual reports; and failed to appropriately designate a permitted hazardous waste management facility on its manifests.
Bradley will pay a $75,000 penalty to resolve the RCRA violations. The CAFO also requires Bradley to certify that it is in full compliance with RCRA and its implementing regulations.