On November 4, 2015, U.S. EPA filed a Consent Agreement and Final Order (CAFO) that simultaneously commences and concludes an action alleging violations of certain hazardous waste requirements under the Resource Conservation and Recovery Act (RCRA), against Metal Improvement Company, LLC, at its facility in Shelby Township, Michigan. The allegations included: storage of hazardous waste for more than 90 days without a license; failure to meet all the conditions necessary to exempt it from the requirement to obtain a license; failure to make hazardous waste determinations; failure to comply with the contingency plan requirements; failure to conduct, document and retain on-site records of waste container inspections; and failure to comply with universal waste requirements.
Metal Improvement Company, LLC, agreed to pay a civil penalty of $80,000. The CAFO does not include any injunctive relief because of Metal Improvement Company's complying actions since the inspection and its response to the Notice of Violation.