Case 01EPA / CERCLA
A 28-facility operator received simultaneous EPA notices of violation across three states — hazardous waste misclassification, improper manifest documentation, and a discharge permit lapse at two properties.
The incoming compliance director inherited a 19-month documentation backlog and an operations team with no dedicated regulatory staff. The penalty clock was running. External counsel was quoting $380,000 in anticipated fines before any remediation costs.
Regulatory Exposure
RCRA Subtitle C misclassification
40 CFR Part 262 manifest violations
NPDES permit lapse — 2 facilities
CMS Form 2567 deficiencies pending
Counsel embedded a dedicated compliance team within six days of engagement.
01Conducted emergency waste stream audit across all 28 facilities in 14 days
02Corrected and resubmitted all manifests; reclassified waste streams under 40 CFR 261
03Negotiated compliance schedule with EPA Region III — penalty reduced to corrective action only
04Reinstated NPDES permits with zero discharge violations on record
05Delivered full CMS survey readiness package before next survey window
$341,000
in penalties eliminated
VP of Operations
Multi-state senior care operator, 28 facilities
11 weeks to full resolution