Tradebe Treatment and Recycling Northeast, LLC Settlement Information Sheet

(Washington, DC - December 12, 2018) - The U.S. Environmental Protection Agency (EPA) and the U.S. Department of Justice (DOJ) today announced a proposed settlement with Tradebe Treatment and Recycling Northeast, LLC that resolves alleged violations of the Resource Conservation and Recovery Act (RCRA) and the Clean Air Act (CAA) at the company’s hazardous waste treatment, storage and disposal facilities in Meriden and Bridgeport, Conn.

• Overview
• Violations
• Injunctive Relief
• Pollutant Impacts
• Health Effects and Environmental Benefits
• Civil Penalty
• Comment Period
• Contact

Overview of Company

Tradebe Treatment and Recycling Northeast, LLC (Tradebe) owns and operates hazardous waste treatment, storage and disposal facilities in Meriden and Bridgeport, Connecticut. Tradebe is a wholly-owned subsidiary corporation of Tradebe Environmental Services, LLC, a privately-held Delaware corporation with its headquarters in Merriville, Indiana.  Tradebe Environmental Services is one of several divisions of Tradebe, a privately-held company based in Barcelona, Spain, that employs over 2,300 people and operates 85 facilities in Europe, the Middle East and the United States.  

Violations

The case involves alleged violations of both the Resource Conservation and Recovery Act (RCRA) and the Clean Air Act (CAA).  The alleged RCRA violations include failures to comply with the 40 C.F.R. 264, Subpart BB and CC standards and requirements for hazardous waste tanks, equipment leak inspections, and recordkeeping.  There were additional RCRA violations involving site security, storage of hazardous waste at unauthorized locations, tank overflow equipment maintenance, hazardous waste release reporting, and others. The alleged CAA violations primarily involve National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart DD, which applies to hazardous waste treatment, storage and disposal facilities (TSDFs) that handle off-site wastes and that are major hazardous air pollutant sources.  

Injunctive Relief

Under the settlement, Tradebe will install at both facilities equipment to control the emissions of hazardous waste air pollutants and volatile organic compounds (VOC), which can pose a range of short- and long-term adverse health effects. Tradebe will replace its current air controls, which use carbon to absorb hazardous waste emissions, with new thermal oxidizers that will burn up and destroy the emissions.  Tradebe will also purchase new emissions leak detection equipment for both facilities.

The specific injunctive relief required by the Consent Decree includes the following:

• Installation and testing of new thermal oxidizers for air emission control at both facilities to replace their existing carbon adsorption systems.  These new controls will be in place within nine months after the consent decree is entered.
• Installation of new tank overflow level monitoring equipment at the Meriden facility to replace its current “bubble system” for overfill protection control.  The new system will be in place within four months after consent decree entry.
• Proper paving and maintenance of outside parking lots and outside areas of the Meriden facility, where hazardous waste-containing trucks are parked or stored.  Tradebe has already repaired/repaved the specific areas identified in the decree.
• The consent decree does not include injunctive relief for the alleged CAA Subpart DD violations because the facilities have obtained minor source air permits in August and are no longer subject to Subpart DD; instead, the consent decree requires compliance with the new minor air permits.

The total estimated value of the injunctive relief and other actions required under this proposed settlement is at least $920,000. 

Pollutant Impacts

Air emissions from hazardous waste storage tanks, pipes, valves and other equipment are known or are suspected to cause cancer, birth defects and seriously impact the environment.

Health Effects and Environmental Benefits

RCRA requires effective monitoring and control of air emissions from hazardous waste storage tanks, pipes, valves and other equipment.  Under the settlement agreement, Tradebe will purchase new emissions leak detection equipment for both facilities and will replace its air pollution systems with new thermal oxidizers that will burn up and destroy emissions.

Civil Penalty

Tradebe will pay a civil penalty of $525,000.

Comment Period

The proposed settlement, lodged in the U.S. District Court for the District of Connecticut, is subject to a 30-day public comment period and final court approval.  Information on submitting comment is available at the Department of Justice.

For more information, contact:

Steven J. Viggiani
Senior Enforcement Counsel
Office of Environmental Stewardship
U.S. Environmental Protection Agency, Region 1
(617) 918-1729
viggiani.steven@epa.gov