On February 25, 2020, Region III entered into a Consent Agreement with, and issued a Final Order to, AERC Acquisition Corporation, dba AERC Recycling Solutions, A Clean Earth Company (AERC), settling violations of RCRA Subtitle C that EPA inspectors observed during an inspection of the company's facility in Richmond, Virginia (Facility). The settlement will ensure that, in the future, the company will properly contain and manage hazardous waste lamps at the Facility. At the Facility, the company collects waste lamps, stores them and prepares them for shipment and further processing. EPA considers these waste lamps to be hazardous waste. As a result, the Facility is required to comply with the Resource Conservation and Recovery Act (RCRA) and the federally-authorized Virginia Hazardous Waste Management Regulations. RCRA is designed to protect human health and the environment by providing for the safe management of such hazardous wastes.
During the inspection of the Facility, and through subsequent communications, the EPA inspectors observed that the Company: (1) operated a hazardous waste treatment, storage, and disposal without a permit or interim status; (2) failed to mark containers with words, Hazardous Waste ; (3) failed to mark containers of hazardous waste with their accumulation start date; (4) failed to keep hazardous waste containers closed except when adding/removing waste; (5) failed to keep hazardous waste in containers that were structurally sound to avoi