On December 4, 2023, EPA Region 6 issued an Expediated Settlement Agreement (ESA) under its authority pursuant to the Resource Conservation and Recovery Act (RCRA) to Union Processing Systems located in Conroe, TX. The ESA was issued in response to violations of: 30 TEX. ADMIN. CODE ? 335.152(a)(4) and 40 C.F.R. ? 264.71(a)(2)(v) requiring that manifests be submitted to EPA?s e-Manifest system within 30 days of the date the waste was delivered; and 30 TEX. ADMIN. CODE ? 335.152(a)(4) and 40 C.F.R. ? 265.1311(b)(2) requiring that manifests be certified at the time of submission.
The ESA requires Union Processing Systems to correct the violations by certifying the manifests and pay a fine of $12,500. Union Processing Systems must respond to EPA Region 6 within 30 days of receipt of the ESA.