EPA and Mercedes-Benz enter into consent agreement after SC plant inspection
The U.S. Environmental Protection Agency (EPA) and Mercedes-Benz Vans LLC (MBV) entered into a consent agreement (CA) in June to address alleged Hazardous Waste Regulations violations, according to an article posted by Mitchell, Williams, Selig, Gates, and Woodyard law firm on Tuesday.
According to the CA, the EPA and inspectors with the South Carolina Department of Health and Environmental Control conducted a Compliance Evaluation Inspection (CEI) under the Resource Conservation and Recovery Act (RCRA) on April 10, 2024, at MBV’s Ladson, South Carolina plant, where Sprinter and eSprinter vans are assembled for the U.S. and Canadian markets.
Inspectors documented multiple alleged violations during the inspection.
MBV agreed to a civil penalty of $51,300, but neither admits nor denies allegations outlined in the CA, the release says.
The CA notes that MBV’s plant includes a body shop, paint body shop, and expanded assembly building. The company’s Hazardous Waste Generator Notification characterizes the facility as a large quantity generator (LQG) of hazardous waste.
During the inspection, it was found that MBV did not make accurate hazardous waste determinations, including a 5-gallon step container labeled “Excluded Solvent Contaminated Wipes Non-Hazardous, Flammable” in a rework area. It held paint-contaminated personal protective equipment (PPE). A facility representative stated that the PPE was hazardous debris and not a wipe.
Another 55-gallon container in a touch-up paint mix room was labeled in the same way but held hazardous debris and not wipes, the CA states.
A third 1-gallon container was labeled “spent OzzyJuice,” the CA says. It had at least 1 inch of clear yellow liquid in the paint shop maintenance area. Facility representatives were unable to identify the contents of the container.
In Satellite Accumulation Areas (SSA), a 5-gallon container with hazardous waste paint debris was sitting on plastic and surrounded by absorbent pads near the primer purge recovery system. Two mop buckets with solvent-contaminated water were found in the mix room storage area. In both cases, no one was actively adding or removing the waste, and the containers were not labeled as hazardous waste.
Inspectors also observed a release of primer paint underneath a pump for the primer purge recovery system’s grated secondary containment, the CA says. Facility representatives explained that the release happened the day before and was being allowed to dry before being cleaned up.
A bin in the loading area outside the mix room area was labeled “Scrap Metal Bin” and contained paint-contaminated PPE and multiple paint containers, many of which still contained paint and some of which had drained into the bottom of the bin, the CA says. It adds that inspectors observed hazardous waste paint released inside the scrap metal bin.
A quick reference guide included in the company’s contingency plan did not include a map of the facility showing where hazardous wastes are generated, accumulated, and treated, nor a street map of the facility, water supply locations, or the identification of on-site notification systems, the CA says.
MBV was also unable to produce the job descriptions for the contract employees managing hazardous waste and training records for three of the respondent’s employees responsible for signing and or managing the hazardous waste manifests and records, the CA says.
It says that MBV provided all but one of the records on July 30, after the inspection, and explained that the records were present at the faculty during the CEI. The exception was an employee’s hazardous waste training record that was not present at the facility during the CEI. The record was obtained on April 17 and included in the facility’s onsite files.
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