NEW CASTLE —
Editor, The News:
I am responding to Monday’s article, “Ellwood business settles violation with fine,” which reported Ellwood Quality Steels Company agreed to pay $150,000 to the Environmental Protection Agency to settle alleged violations of federal hazardous waste regulations.
Our emphasis is on operating in a manner that does not harm people or the environment.
The EPA made an unscheduled visit to EQS in New Castle Sept. 28, 2010, and assessed an initial fine of $351,000. It was based mainly on the fact the EPA inspector was told during that visit that EQS employees would throw fluorescent light bulbs into the electric arc furnace to dispose of them.
Employees were not aware that under applicable regulations, we are supposed to store such bulbs without breaking them and send them off site for disposal.
In the five years prior to the inspection, EQS purchased approximately 735 fluorescent bulbs. We hired an outside expert who determined, using EPA data and conservative assumptions, that if EQS disposed of every bulb in the furnace during that period, the maximum possible level of mercury release would be more than 12 times lower than the OSHA “permissible exposure level” for an instantaneous exposure and 100 times less than the “Threshold Limit Value” for an eight-hour time-weighted average exposure.
Our failure to dispose of the bulbs in accordance with regulations harmed no one nor the environment.
Remaining violations the EPA alleged claimed we failed to properly label waste containers, and failed to maintain certain inspection and training records. These made no claim of improperly disposed of waste or environmental harm.
We settled with the EPA to save litigation expense, even though we felt the fine was still much too high.
Compliance with environmental and safety regulations is of extreme importance to EQS and Ellwood Group companies.
Robert E. Rumcik
President
Ellwood Quality Steels
New Castle
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