On September 18, 2014, Region 5 filed a Consent Agreement and Final Order (CAFO) commencing and concluding an action against Canton Drop Forge, Inc. of Canton, Ohio, a drop forge that manufacturers parts for industrial turbines, industrial gears, aerospace landing gear, oil field valves, and other industries. The CAFO alleges violations of the Resource Conservation and Recovery Act (RCRA), as amended, 42 U.S.C. §6901 et seq., against Canton Drop Forge for the storage and management of used oil in two on-site surface impoundments (ponds) without a permit or interim status. RCRA requires, in 40 CFR §§ 279.12(a) and 279.22(a), that used oil may only be managed and stored in surface impoundments that meet the same strict requirements and engineering controls of hazardous waste surface impoundments. A faulty and undersized oil-water separator on Canton Drop ForgeÂs site had allowed used lubricating oils to discharge and accumulate in its two ponds. The CAFO requires that Canton Drop Forge submit for review and approval a closure plan to the Ohio EPA. The closure plan will require the removal of all used oil and water emulsion, oily sludge, and oil-impacted soils from in and around both ponds. In addition to the injunctive relief, the CAFO requires Canton Drop Forge to pay a $431,100 civil penalty.