On June 5, 2019, EPA Region 3 submitted a Litigation Report to the Department of Justice regarding violations of the Resource Conservation and Recovery Act (RCRA) by the Heritage-Crystal Clean, Inc. (HCC) facility formerly operating in Fairless Hills, PA. This Report will supplement a Litigation Report previously submitted by Region 6 regarding HCC facilities in that region. Regions 4, 5 & 8 will also be joining this national enforcement action. The violations related to the Fairless Hills HCC facility include: failure to properly identify and manage hazardous waste; operating as a Treatment, Storage, and Disposal facility without first obtaining a permit; shipping hazardous waste offsite without using a manifest; and failure to comply with the RCRA air emission requirements. These violations were discovered after a joint Region 3/Headquarters inspection conducted March 12 & 13, 2018. The Pennsylvania Department of Environmental Protection participated on the March 2018 inspection and was invited to join in the referral