Container Life Cycle Management Desk Statement

November 2017

The U.S. Environmental Protection Agency has issued Notices of Violation to Greif, Inc. (Greif), and Container Life Cycle Management, LLC (CLCM), doing business as Mid-America Steel Drum, for alleged violations of the Resource Conservation and Recovery Act and Clean Air Act, based on inspections and sampling at three facilities in Wisconsin.

EPA alleges that at facilities in Milwaukee, St. Francis, and Oak Creek, Greif and CLCM violated RCRA regulations regarding the storage and transportation of hazardous waste, as well as recordkeeping and reporting requirements. EPA also alleges the companies unlawfully treated hazardous waste in an incinerator at the Oak Creek facility when burning material that exited from drums.

EPA alleges violations of the CAA at the St. Francis and Oak Creek facilities. At the St. Francis facility, the companies allegedly failed to control volatile organic compounds and hazardous air pollutant emissions, obtain proper permits, meet work practice standards and recordkeeping requirements, and adequately respond to EPA’s request for information. At Oak Creek, EPA alleges that CLCM and Greif failed to comply with requirements associated with the combustion of hazardous waste, including demonstrating compliance with emission limits, performance testing, monitoring, notifications, recordkeeping and reporting.

EPA, in coordination, with the Wisconsin Department of Natural Resources and other governmental agencies, continues to investigate and intends to take appropriate action.  EPA is committed to communicating publicly available information regarding its efforts and has established a webpage, which will be updated with related information. The companies have 30 days to respond to EPA regarding the allegations in these NOVs. These violations of RCRA and CAA that EPA has alleged are in addition to the allegations in the NOVs WDNR sent to the companies earlier this year.

For more information: EPA Investigating Milwaukee Company for Potential Environmental Violations