# P & L DEVELOPMENT, LLC
> **Administrative - Formal** · FY2025 · — · Final Order With Penalty
## Case
- **Activity ID:** `3604544024`
- **Case Number:** 04-2025-4001
- **Type:** Administrative - Formal
- **Lead:** EPA
- **Outcome:** Final Order With Penalty
- **Penalty assessed:** —
- **Cost recovery:** —
- **Compliance action $:** —
- **Multimedia (multi-env):** —
## Defendants
- P & L DEVELOPMENT, LLC (complaint) (settlement)
## Summary

SEPTEMBER 22, 2025 - CONSENT AGREEMENT

On December 8, 2022, EPA and the South Carolina Department of Health and Environmental Control (DHEC) conducted a RCRA compliance evaluation inspection (CEI) at the Respondent?s Facility.
On February 27, 2023, EPA mailed the Respondent an Opportunity to Show Cause Letter (Show Cause Letter) and a CEI Report documenting its findings from the December 8, 2022, CEI.
On March 10, 2023, Respondent provided EPA a response to the Show Cause Letter and CEI Report.
Inspectors observed solvent-contaminated wipes, which are used for cleaning the First Aid Lines machinery, left to dry on the counters before disposal.
The inspectors identified the following CAAs: MON Storage Area CAA, MON Manufacturing CAA, QC Lab CAA, and Baghouse CAA. 
Inspectors observed one cubic yard tote of liquid/sludge nicotine waste with dried waste NPR on top of the tote; another cubic yard tote of liquid/sludge nicotine waste with accumulated NPR waste in the open funnel of the tote and in the secondary containment pallet of the tote in the MON Storage Area CAA.
Inspectors observed one cubic yard tote containing liquid/sludge nicotine waste with a cap that was not securely closed and contained a hole, and another cubic yard tote containing liquid/sludge nicotine waste with an open funnel that was not securely closed and latched in the MON Storage Area CAA.
Inspectors reviewed the Facility's hazardous waste CAA weekly inspection logs which showed that the Responde

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*Source: [EPA ECHO](https://echo.epa.gov/) · AI Analytics · CC0 1.0*