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The U.S. Environmental Protection Agency (“EPA”) and Mercedes-Benz Vans, LLC, (“MBV”) entered into a June 16th Consent Agreement (“CA”) addressing alleged violations of the Hazardous Waste Regulations. See Docket No. RCRA-04-2025-4000(b).
The CA provides that MBV operates an assembly plant in Ladson, South Carolina that assembles Sprinter and eSprinter vans for the United States and Canadian markets.
The plant includes the following:
- Body Shop.
- Paint Body Shop.
- Expanded Assembly Building.
The facility has previously submitted a Hazardous Waste Generator Notification that characterized it as a Large Quantity Generator (“LQG”). Further, the waste profile records are stated to have indicated that the waste streams have included used solvent and paint waste designated with various EPA Waste Codes, including, but not limited to, D001, D035, F003, and F005.
EPA personnel and inspectors of the South Carolina Department of Health and Environmental Control are stated to have conducted a Resource Conservation and Recovery Act (“RCRA”) Compliance Evaluation Inspection of the facility on April 10, 2024.
The inspectors are stated to have observed that the facility had not made accurate hazardous waste determinations. Further, the inspectors are stated to have observed open containers in the satellite accumulation area with no one actively adding or removing waste. The containers were also not labeled with the words “Hazardous Waste” or an indication of the hazards of the contents.
Additional alleged violations include:
- Primer purge recovery system's grated secondary containment underneath a pump contained a release of primer paint.
- 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.
- Contingency Plan did not include a map of the Facility showing where hazardous wastes are generated, accumulated, and treated.
- Facility is unable to produce certain records.
MBV is stated to have provided all but one of the records described in the preceding paragraph and explained that such records were present at the facility during the inspection but were not provided to EPA at the time. The exception was one employee's hazardous waste training record. The missing record was subsequently obtained.
MBV neither admits nor denies the factual allegations set forth in Section 4 of the CA.
A civil penalty of $51,300.00 is assessed.
A copy of the CA can be downloaded here.
