Based upon EPA inspections and information provided by the company, EPA has concluded that the company, in its operations at its Newark facility, violated RCRA requirements regarding the storage of hazardous waste without a permit, violated various requirements regarding air emissions standards (40 CFR Part 265, subparts BB and CC) and failed to make a hazardous waste determination. EPA also concluded the Defendant failed to submit timely EPCRA Section 313 reports to the agency and to the State of New Jersey for seven chemicals it used in calendar year 2004.
Under the CD, the Defendant is agreeing to pay a civil penalty and to ensure compliance with applicable RCRA and EPCRA requirements.