NEIC
     SUMMARY OF CRIMINAL PROSECUTIONS RESULTING
     FROM ENVIRONMENTAL INVESTIGATIONS
     April 1987
                                  vvEPA

national enforcement investigations center
           denver federal center  bldg 53, box 25227 denver, co 80225

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 UNITED  STATES  ENVIRONMENTAL  PROTECTION AGENCY
 OFFICE  OF  ENFORCEMENT AND COMPLIANCE MONITORING
SUMMARY OF CRIMINAL PROSECUTIONS RESULTING
FROM ENVIRONMENTAL INVESTIGATIONS
April 1987
Office of Criminal Investigations
National Enforcement Investigations Center
Denver, Colorado
"The attached summary  is based on the best available  information.
Anyone relying on this summary should verify  the  information with
the Clerk of the Court for the United States District Court, where
the official records are filed."

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                           TABLE OF CONTENTS


Section I   	 Resource Conservation and Recovery Act (RCRA)

Section II  	 Clean Air Act (CM)

Section III 	 Clean Water Act (CWA)

Section IV  	 Federal Insecticide,  Fungicide,  and RodentLcide
                         Act (FIFRA)

Section V   	 Toxic Substances Control Act (TSCA)

Section VI  	 Comprehensive Environmental Response, Compensation
                         and Liability Act (CERCIA)

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                                SECTION I

              Resource Conservation and Recovery Act (RCRA)
Resource Conservation and
  Recovery Ace (RCRA) 	42 USC S§ 6901-6991
                                                       PL 94-580
                                                       PL 96-482
                                                       PL 98-616

Emergency Planning and Community
  Right to Know Act (EPCRA) 	42 USC 11045
                                                       PL 99-499

Hazardous Materials Transportation
  Act (HWTA) 	 42 USC §§ 1801-1813
                                                       PL 93-633

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                                                                                                                 04/22/87  -  I
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED WITH
                                   RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) AUTHORITY
Oefendant(s)/0ocket No./Court
                                         Facts  and  Status
A  C. Lawrence Leather Company,
Lawrence K. Barber
Francis E  Stone
Richard S. Johnson
Weymouth E. Marshall
Robert F  Goodspeed
82-00037
(0 N H )
Inc.
                EPA Region I
Facts:  Wastewater discharged from large leather tanning facility in Winchester  into
Ashuelot River in violation of NPDES permit.   Plug in pipe removed,  allowing  dis-
charge to bypass facility's treatment plant and flow directly from holding  tank  into
river, despite fact that Company had received $238,420 from EPA in research and  grant
funds for demonstrating process to meet best available treatment standards  for tan-
ning industry covering all pollutants generated during manufacturing operations.
Marshall was president; Goodspeed, vice president; Johnson, plant superintendent;
Stone, director of manufacturing and Barber was forner director of maintenance and,
engineering.

12/15/82:  68-count indictment returned against Company and employees charging:

     Company - One count conspiracy [18 U.S.C.  §371); 5 counts mail  fraud [18 U.S.C.
     §1341], 43 counts discharge of pollutants in violation of NPOES permit under
     Clean water Act, Sees. 301(a) and 309(c)(l) [33 U.S.C. §§1311(a) and
     1319(c)(l)]; 15 counts submittal of false stateaents [18 U.S.C. §1001],  and four
     counts malting false claims to EPA [18 U.S.C. §287].

     Barber - One count conspiracy, three counts mail fraud, 43 counts discharges in
     violation of Clean Water Act, one count false statements and four counts false
     claims

     Stone - One count conspiracy, two counts mail fraud, 43 counts discharges  in
     violation of Clean Water Act and seven counts false stateaents.

     Johnson - One count conspiracy, two counts mail fraud, 43 counts discharges in
     violation of Clean Water Act and seven counts false statements.

     Marshall - 43 counts of discharges in violation of Clean Water Act

     Goodspeed - 43 counts of discharges in violation of Clean Water Act.

03/10/83   Individual defendants each pled guilty after Government's opening argument
at trial.

     Barber and Stone - Five counts under Clean Water Act and one count  false
     statements.

     Marshall and Goodspeed • Five counts under Clean Water Act
                                             Johnson - Ten counts under Clean Water Act.

                                        04/07/83-  Company convicted by jury on all counts
                                        sentencing information)
                                                             (See following section for
A. C  Lawrence Leather Company,
Weymouih E. Marshall
Robert F  Goodspeed
Francis E  Stone
Bernard Davis
83-00007
(D.N.H.)
Inc.     Facts:   Same defendants plus Oavis,  foreman at the Winchester facility, generated.
        stored and released degreasing solvent (tetrachloroethylene) and its sludges and
        conspired to cover up the fact by falsifying reports.

        01/25/83-  Company and individuals charged \r\ second seven-count indictment-

             Company - Two counts of storage of hazardous waste without permit in violation
             of RCRA, Sec  3008(d)(2)(A) [42 U.S C  §6928(d)(2)(A)], one count disposal of
             hazardous waste without permit in violation of RCRA, Sec  3008(d)(2)(A). t*o
             counts submittal of false statements to EPA [18 U.S.C.  §1001]; one count failure
             to notify of release of hazardous substances in violation of CERCLA, Sec  103(3)
             [42 U.S.C. §9603(0)]; and one count failure to notify of existence of Hazardous
             waste facility in violation CERCLA. Sec. 103(c) [42 U.S.C. §9603(c)].

             Marshall - One count failure to notify of existence of hazardous waste facility.

             Goodspeed - One count storage of hazardous waste and one count failure to notify
             of existence of hazardous waste facility.

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                                                                                                                 04/2Z/87 -  2
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED WITH
                               RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)  AUTHORITY (cent.)
Defendant s)/Docket NO /Court
                                                 Facts and  Status
A. C. Lawrence Leather Company, Inc.
  (cont.)
A  C. Lawrence Company,
Robert F  Goodspeed
83-00020
(O.N.H )
Inc
            EPA Region I (cont.)

     Stone - One count storage of hazardous waste,  one count disposal  of  hazardous
     waste, two counts false statements, one count  failure  to notify of release of
     hazardous substances and one count failure to  notify of existence of hazardous
     waste facility.

     Davis - One count storage of hazardous waste,  one count disposal  of  hazardous
     waste and one count failure to notify of release of hazardous  substances

04/29/83:   Superseding information filed charging two additional  counts:

     Company - One count subnittal of false statements under RCRA,  Sec. 3008(d)(3)
     [42 U S C  §6928(d)(3)].

     Goodspeed - One count failure to notify of release of  hazardous  substances  under
     CERCLA, Sec  103(b) [42 U.S.C.  §9603(b)].

04/29/83   Company and three individual defendants  pled guilty as follows-

     Company - One count storage of hazardous waste,  one count disposal of hazardous
     waste, one count failure to notify of release  of hazardous substances, one  count
     failure to notify of existence of hazardous waste facility and one count sub-
     mi ttal of false statements under RCRA, Sec. 3008(d)(3)

     Marshall - One count failure to notify of existence of hazardous  waste facility.

     Goodspeed - One count failure to notify of release of  hazardous  substances  and
     one count failure to notify of existence of hazardous  waste facility.

     Stone - One count storage of hazardous waste,  one count failure  to notify of
     release of hazardous substances and one count failure  to notify  of existence of
     hazardous waste facility

04/29/83'   Defendants sentenced simultaneously under Clean  Water Act  and  RCRA indict-
ments (and superseding information) as follows.

     Company - Fined under first indictment   $5,000 on conspiracy count; $200 on
     each mail fraud count for sum of SI,000, $10.000 on each of five Clean Water Act
     counts for sum of $50,000, $1,000 on each false statement count for  sum of
     $15,000; and $1.000 on each false claims count for sum of $4,000, all totaling
     $75,000.  Under second indictment.  $10,000 on RCRA storage count,  $50,000  on
     RCRA disposal count, $5,000 on CERCLA. Sec. 103(b) count; and $5,000 on CERCLA.
     Sec.  103(c) count, for total of $70,000.  Under RCRA false statement count.
     $5,000, for grand total of $150,000 under all  charges    Company also placed on
     5 years probation under each set of charges, to run concurrently, and required
     to repay $238,420 it had received from EPA in federal  grant funds

     Barber - Under first indictment only, for five Clean Water Act counts.  1 year
     imprisonment (execution suspended) plus 2 years probation and 200 hours of  com-
     munity service activities, and $2.500 fine on each count for sum of  $12.500. for
     false statement count. 1 year imprisonment (execution  suspended)  plus 2 years
     probation (to be served concurrently) and $5,000 fine  for total  of  $17,500.

     Stone - Under first indictment:  same sentence as for  Barber.   Under second
     indictment   for RCRA storage count, 1 year imprisonment (execution  suspended)
     plus 2 years probation (to be served concurrently) and $5,000 fine,  for 2 CERCLA
     counts and one RCRA storage count, 1 year imprisonment (execution suspended)
     plus 2 years probation (also to be served concurrently) $5,000 on RCRA count
     and $2,500 fine on each CERCLA count for total of $10,000 under second indict-
     ment and grand total under both indictments of $27,500

     Johnson - Under first indictment, for 10 Clean Water Act counts:   1 year
     imprisonment (execution suspended) plus 2 years probation and 200 hours of com-
     munity service and $2,500 fine on each count for sum of $25,000 with all but
     $5,000 suspended.

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                                                                                                                04/22/87 - 3
                                         ENVIRONMENTAL  INVESTIGATIONS  INITIATED WITH
                               RESOURCE CONSERVATION AND  RECOVERY ACT  (RCRA) AUTHORITY (cont.)
Defendant(s)/Docket No /Court
                                                      Facts and Status
A  C  Lawrence Leather Company,  Inc.
  (cont.)
Robert E  Derecktor of
  Rhode Island, Inc
151 East Post Road Corporation,
Rooert E.  Derecktor
86-022
(D  R I)
Johnson & Towers,
Peter Angel
Jack W  Hopkins
83-00083
(D.N J )
Inc
                    EPA Region  I (cont.)
             Marshall  - Under first indictment for five Clean Water Act counts-   1 year
             imprisonment  (execution suspended) plus 2 years probation and 200 hours of com-
             munity  service and $2,500 fine on each count for sum of $12,500.   Under second
             indictment, for CERCLA. Sec. 103{c) count, 1 year imprisonment (execution sus-
             pended) plus  2 years probation (to be served concurrently) and $5,000 fine (with
             all  but 12,500 suspended),  for grand total under both indictments of $17,500
             (less $2,500  suspended)

             Goodspeed - Under  first indictment for five Clean Water Act counts.   1 year
             imprisonment  (execution suspended) plus 2 years probation and 200 hours of com-
             munity  service activities and $2,500 fine on each count for sum of J15.000
             Under second  indictment; for 2 CERCLA counts. 1 year imprisonment (execution
             suspended) plus 2  years probation (to be served concurrently) and $5,000 fine on
             each count for sun of $10,000 under second indictment and grand total under bom
             indictments of $22,500.

             Charges against Davis dismissed.

        04/12/84   Company, Barber, Stone. Johnson, Marshall and Goodspeed all piaced on EPA
        master list  of persons  debarred, suspended or voluntarily excluded under  40 CFR
        Part 32 from participation in EPA-assisted programs for period of 3 years (to
        04/11/87)

        Facts.  Robert E   Oerecktor is president of Derecktor. Inc., operator of  shipyard  for
        building  and repairing  vessels located on Coddington Grove  in Middletown   Post Roaa
Inc     corporation  owns farm in Portsmouth occupied by Robert E. Oerecktor   Transformers
        from shipyard  leaking PCBs found buried at farm.

        05/20/86.  46-count indictment returned charging each defendant as follows.

             Derecktor, Inc. -  6 counts  under TSCA for PCB violations [15 U.S.C   §§2614(l)(c)
             ana  2615(b)j, two  counts failing to report release of  PCB and asbestos  in  vio-
             lation  of CERCLA,  Sec  103(b) [42 U.S C  §9603(b)],  29  counts discharging  pollu-
             tants from drydock without  permit in violation of Clean Water Act,  Sees   301(a)
             and  309(c)(l) [33  U.S C. §§1311(a) and 1319(c)(l)].  two counts storage  and dis-
             posal of  hazardous wastes without permit  in violation  of RCRA, Sec.  30Q8(d)(2)
             [42  U.S.C. §6928(d)(2)], four counts violating NESHAP  work practice standards
             for  asbestos  removal  in violation of Clean Air Act,  Sees.  112 and  113(c)(l) [d?
             U S  C.  §§7413(c)(l)(C). 7412(c)(l)(B) and 7412(e)(5)]  and one count violation of
             Hazardous Materials Transportation Act (HHTA)  [49 U  S  C  §1809(b)]

             Derecktor - Seven  counts PCB  violations  under  TSCA,  one count under HHTA,  one
             count  failing to report release of hazardous  substance (PCBs) under CERCLA, one
             count conspiracy [18  U.S.C  §371], and 29 counts  discharging pollutants  without.
             permit

             East Post Road Corporation  -  Two counts  PCB  violations and one count failure  tc
             report  release of  hazardous substance  (PCBs).

        12/29/86- Derecktor, Inc  was  sentenced  to $600.000  fine on its  plea of guilty to
        24 counts of violating  the Clean Water Act  and one  count  each  of  violating the Clean
        Air Act and  CERCLA   Suspension  of $200.000 depends  upon  restitution  of that amount
        to the Hazardous Waste  Emergency Response  Fund.   Robert Oerecktor was sentenced to
        $75,000 fine on  his plea  of  guilty to violating  three  counts of TSCA  and to 5 years
        of probation for an additional  count of  violating  TSCA

                        EPA  Region II
        Facts.  Over 3-day period, federal agents  saw workers  attach pump to  tank containing
        hazardous wastes  and  pump substantial  quantities  of degreasers  and  other industrial
        chemicals into trench,  including dichlorobenzene,  dichloronethane,  chlorobenzene,
        tetrachloroethylene,  toluene and ethylbenzene.   On third  day,  pollutants spilled into
        Parker Creek.   Angel  was  former plant  supervisor,  Hopkins worked  as  plant foreman  ana
        Johnson was  vice  president for operations.

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                                                                                                                 04/22/87 - 4
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED WITH
                                RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) AUTHORITY (cont.)
 Defendant(s)/Docket  No  /Court
Johnson &  Towers,  Inc.
   (cont )
Peter Johnson
86-3134C
(0 N J  )
Fried  Industries, Inc
85-58
(D N J  )
Charles Colbert
Jack Colbert
Signo Trading International, Ltd.
SCI Eouipment and Technology, Ltd.
85-1134
(SO  NY)
                                 Facts and Status
            EPA Region II (cont.)
03/29/83:  Five-count indictment returned against Company,  Angel  and Hopkins charging
each defendant with three counts disposal of hazardous wastes without permit in vio-
lation of RCRA, Sec. 3008(d)(2) [42 U.S C.  §6928(d)(2)], one count discharge of
pollutants without NPOES permit in violation of Clean Water Act,  Sees  301 and 309
(c)(l) [33 U.S C  §§1311 and 1319(c)(l)]. and one count conspiracy [18 U S.C.  §371].
                                        07/08/83
                                        fine
           Company pled guilty to three counts under RCRA and sentenced to $20,000
09/06/83   Substantive RCRA charges against individuals dismissed,  leaving aiding and
abetting counts under RCRA plus substantive Clean Water Act and conspiracy counts.

08/15/84   On aopeal, Third Circuit reversed dismissal of substantive RCRA counts
against individuals and remanded case to district court for trial  of those counts.

10/10/84   Angel filed petition for certiorari in United States Supreme Court.   Gov-
ernment subsequently filed response in opposition to petition.

02/19/85   Supreme Court denied Angel's petition for certiorari

01/02/86   Angel and Hopkins entered into pretrial diversion agreement with United
States Attorney's Office.   Indictment dismissed against each.

03/31/86.   Information filed charging Peter Johnson with one count discharging  pol-
utants without NPOES permit in violation of Clean Water Act, Sees  301 and 309(c)(l)
[33 U S C.  §§1311 and 1319(c)(l)].

04/30/86   Johnson pled guilty to Clean Water Act count.

06/17/86   Johnson sentenced to $2.500 fine.

Facts   Manufacturer of cleaning agents and detergents stored and disposed of indus-
trial chemicals containing methylens chloride, trichloromethane, phenanthrene and
bis-phthalate without permit and without notification to EPA.

07/31/85.   Company waived indictment and pled guilty to two-count information filed
same date charging one count storage of hazardous waste without permit in violation
of RCRA, Sec. 3008(d)(2) [42 U S C.  §6928(d)(2)] and one count failure to notify of
release of hazardous substance under CERCLA, Sec. 103(b) [42 U S C  §9603(0)]   Com-
pany sentenced on same date to $40,000 fine

Facts-   President (Charles Colbert) and vice president (Jack Colbert) of cnemical
trading business in Mount Vernon shipped recycled chlorinated solvent mixture con-
taining only IX of ordered chemicals to chemical import business in Zimbabwe in
sophisticated, international "bait and switch" scheme   Case investigated by FBI and
Agency for International Development

12/12/85   32-count indictment filed charging Jack Colbert. Charles Colbert and botrt
companies with one count conspiracy, 15 counts wire fraud [18 U.S C  §1343], six
counts mail fraud [18 U.S.C. §1341], six counts false statements [18 U S C  §1001],
one count false claims [18 U S C  §287] and two counts transportation of false
securities [18 U.S C.  §2314]   Charles Colbert and Jack Colbert also charged with one
count obstruction of justice [18 U S C  §1503].

05/08/86   30-count superseding filed charging Charles and Jack Colbert with one
count conspiracy, 15 counts wire fraud, six counts mail fraud,  six couts false  state-
ments, one count making false claims and one count obstruction of justice.  Both
Companies charged with same counts except for obstruction of justice

06/02/86-   Trial began.

06/09/86-   After 6 days of trial, jury verdicts of guilty returned against Charles
and Jack Colbert (27 felony counts each) and against Signo Trading and SCI (25 felom
counts each)

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                                                                                                                 04/22/87  -  S
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED WITH
                               RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) AUTHORITY (cont.)
Defendants)/0ocket No./Court
                                 Facts and Status
Charles Colbert, etc
  (cont.)
Howard J  Nybo
86-91
Frederick C. Kiesinger
86-92
Ouane Simmons
86-93
Will & Baumer, Inc.
86-94
(N D. N Y )
Joseph Tietelbaum
87-75
(0  NJ)
Lackawanna Refuse Removal, Inc.
Northeastern Land Development Co.
Peter lacavazzi
82-00173
(M 0. Pa )
            EPA Region II (cont.)

07/28/86:   Both Colberts sentenced to total  13 years  imprisonment  each  (to  run con-
secutively with other State or Federal  sentences),  $1,350  in  costs under Comprehen-
sive Crime Control  Act and $66,000 restitution.   Jack Colbert also fined additional
$50,000 on conspiracy count.   Each Company fined $250,000  and $1,300  in costs.

Facts.   Discharge of pollutants,  including phosphoric acid, arsenic,  lead,  chromium.
phosphorus, nickel  and manganese, through ditch or  stream  into Ley Creek without
notice to National  Response Center   Company is candle making factory near  Onondaga
Lake   Nybo is executive vice president,  Kiesinger  is vice president  in charge of
manufacturing and Simmons is plant maintenance engineer.

05/02/86.   Each defendant charged under separate indictment,  all  filed  on same date
as follows

     Nybo - Two counts discharging pollutants without permit  in violation of  Clean
     Water Act. Sees  301(a) and  309(c)(l) [33 U.S.C. §§1311(a) amd 1319(c)(l)]  and
     two counts failure to report release of hazardous substance under  CERCLA,  Sec.
     103(b) [42 U.S C.  §9603(b)]

     Kiesinger - Two counts discharge without permit  under Clean Water  Act, Sees.
     301(a) and 309(c)(l) and one count failure to  notify  under CERCLA, Sec.  103(b).

     Simmons - One count under Clean Water Act. Sees. 301(a)  and 309(c)(l).

     Company - Two counts under Clean Water Act, Sees. 301(a) and 309(c)(l),  one
     count under CERCLA. Sec  103(b), one count storage of hazardous waste  without
     permit under RCRA. Sec  3008(d)(2) [42 U.S.C.  §6928(d)(2)],  one count  disoosal
     of hazardous waste without permit in violation of RCRA,  Sec  3008(d)(2)
     [42 U S C  §6928(d)(2)] and  one count conspiracy [18  U.S.C.  §371]

     Defendants each pled guilty  to all charges

06/10/86:   Defendants sentenced as follows

     Nybo - 1 year imprisonment (execution of sentence suspended). 2 years  probation-,
     $24,000 total  fine and 400 hours community service

     Kiesinger - 3 months imprisonment (execution of  sentence suspended),  2 years
     probation, $12,000 total fine and 200 hours community service

     Simmons • 3 months imprisonment (execution of sentence suspended). 2  years  pro-
     bation, $5,000 fine plus $25 special assessment  and 100 hours community service.

     Company - $360.000 total fine ($300,000 stayed)  plus  $225 special  assessment.  3
     years probation with condition that Company commit no violation of environmental
     laws.

Facts   Josepn Tietelbaum, president of LMT Steel of  Hoboken, controls  TNT  Realty
which owns a warehouse in Edison    A semi-trailer abandoned in a vacant lot in Newanr
contained 59 drums of chemicals alleged to have come  from that warehouse

03/03/87   A Federal grand jury in Newark returned a  four-count indictment  charging
Tietelbaum with one count conspiracy in violation of  18 U.S C. Section 371 ana :nree
counts for transporting hazardous waste without a manifest form to an unpermittea
disposal facility in violation of RCRA [42 U.S C. §§6928(d)(l), 6928(d)(2)(A) ana
6928(d)(5)]

               EPA Region III
Facts:   Industrial sludges and wastes deposited at Old Forge Borough sanitary land-
fill site.  Lackawanna denied to  EPA that disposal  had occurred   lacavazzi was pres-
ident of Lackawanna.

11/16/82.   Two-count indictment filed charging:

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                                                                                                                04/22/87 - 6
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED WITH
                               RESOURCE CONSERVATION AND RECOVERY  ACT (RCRA)  AUTHORITY  (cont.)
Defendant 5)/Oocket No./Court
                                 Facts and Status
Lackawanna Refuse Removal, Inc
  (cont.)
Michael Yaron
Barak Yaron
Quality Research Labs, Inc.
  (Commercial Research Labs)
83-00170
(E D  Pa.)
Barak Varon
83-00282
(E 0  Pa )
           EPA Region III (cont.)
     Northeastern and lacavazzi  -  One count failure to  notify  of  existence of hazard-
     ous waste facility in violation of CERCLA.  Sec.  103(c)  [42 U.S.C. §9603(c)].

     Lackawanna - One count making false statements [18 U.S  C. §1001].

04/13/83:   Both Companies pled guilty.   Plea a9reement  contained  confession of  lia-
bility by parties and provision whereby Companies agreed to  comply  with  terms of
administrative order to be issued  under RCRA,  Sec.  3008 ensuring  that  proceeds  of
sale of land owned by Companies would be turned  over to Superfund for  cleanup costs.

05/10/83:   Lackawanna and Northeastern each sentenced to $10.000  fine.   Charges
against lacavazzi dismissed upon his agreement to cooperate.

Facts.  Joint EPA/FBI investigation   Hazardous  wastes, including 1,1.1  trichloro-
ethane, toluene, phenol, cresols,  corrosive acid, benzene, xylene and methylene
chloride generated, stored and systematically dumped onto ground at site and into
drains and toilets at facility in  Corwalls Heights   False responses also made  on EPft
Hazardous Waste activity questionnaire.  Michael Yaron was president,  Principal
owner and chief operator   His brother, Barak Yaron was plant foreman.  April  29.
1983, Michael Yaron and J  Ronald  Nenon (former president and principal owner) were
indicted on four counts of related nonenvironraental charges with regard to their SUQ-
mission of storm damage insurance  claims, mail fraud [18 U.S.C.  51341].   Bruce
Handfinger (former officer of related company) also charged with two counts mail
fraud in connection with false insurance claims

05/02/83   Five-count indictment returned against Company, Michael Yaron and Barak
Yaron charging

     Michael Yaron - Two counts false statements [18 U.S.C.  §10011, two counts  stor-
     age and disposal of hazardous wastes without permit under RCRA, Sec
     3008(d)(2)(A) [42 U S C. §6928(d)(2)(A], and one  count failure to notify of
     release of hazardous substance under CERCLA, Sec   103(b) [42 U S C
     §9603(b)]

     Barak Yaron - One count disposal of hazardous wastes.

     Company - One count failure to notify of release  of hazardous substances  and two
     counts storage and disposal of hazardous waste.

08/16/83:  Superseding  information  filed charging Barak Yaron with one count under
CERCLA, Sec. 103(b)

08/01/83-  Barak Yaron  - Pled guilty to one count  failure to notify of release of
hazardous substance under CERCLA.

08/03/83   Company - Pled guilty to one count disposal of hazardous wastes.

08/23/83.  Michael Yaron - Pled guilty  to  one count  disposal of  hazardous ..astes
without RCRA permit and  one  count  failure  to  notify  of release of  hazardous substance
under CERCLA

09/26/83.  Defendants  sentenced as  follows

      Barak Yaron  - $2,000  fine plus 3  years  probation.

      Company -  $10,000  fine

      Michael Yaron • $5,000  fine plus  2 years imprisonment  (all  but 6 months sus-
      pended) plus  5 years  probation on RCRA count.   On CERCLA count,  $5,000  fine olu
      1  year  imprisonment (all  but  6 months suspended)  and 5 years  probation  (impris-
      onment  and probation  to run  concurrently with RCRA disposal  count).

01/24/84-   Sentence  of Michael  Yaron modified.   Restitution reduced  to  $55.600

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                                                                                                                04/22/87 - T
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED WITH
                               RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)  AUTHORITY (cont.)
Oefendant(s)/0ocket No /Court
                                                                         Facts  and Status
George Henry Garson
  (Barrett Chemical Company)
85-00001
(E 0  Pa.)
Robert Clements,
85-00069
(E.G. Va )
                                                   EPA Region III  (cont.)
                                        Facts-   Waste solvents introduced  into POTW causing  potential  fire and explosion
                                        hazard.   Garson was  71-year-old former president.

                                        01/03/85.   One-count information filed charging defendant with violation of pre-
                                        treaunent standards  under  Clean Water Act,  Sees.  307(b)(l)  and 309(c)(l) [33 U S C.
                                        §§1317(b)(l) and 1319{c)(l)].

                                        01/05/85   Defendant pled  guilty.

                                        01/10/85.   Defendant sentenced to  $2,500  fine  and 3  years probation,  including 2
                                        hours per week community service during first  year.

                 Inc                    Facts.   Failure to notify  EPA  of release  of hazardous  substance in excess  of one
                                        pound from facility  in Alexandria.

                                        04/03/85.   Company entered guilty  plea to one-count  information filed same day charg-
                                        ing failure to report release  of hazardous  substance in violation of CERCLA, Sec.
                                        103(b) [42 U S.C.  §9603(b)]

                                        04/26/85   Company sentenced to and paid  (4,000 fine.

                                                        EPA  Region IV
Arthur J.  Greer                         Facts   Proprietor and operator of four now defunct  hazardous waste  handling com-
85-00105                                panies based in Orlando, endangered employees  by directing  them to test chemicals
(M 0  Fla )                             such as cyanide. 1,1.1-tnchloroethane, toluene, methyl ethyl ketone and xylene, by
                                        sniffing samples or  lighting them in soft drink cans,  rather than by performing
                                        required chemical  analysis.   Also, dumping 1,000 gallons of waste,  primarily 1,1.1-
                                        tnchloroethane, and mis label ing drums of hazardous  waste as dirt.

                                        12/17/85   33-count  indictment charging 23 counts mail fraud [18 U S.C  §1341],  one
                                        count disposal of hazardous waste without permit under RCRA, Sec  3008(d)(2)(A)
                                        [42 U S.C  §6928(d)(2)(A)j, one count failure  to notify of  release of hazardous  sun-
                                        stance under CERCLA, Sec  103(b) [42 U S C  §9603(b)], one  count making false  claim
                                         18 U.S C  §287],  one count nislabeling hazardous waste under RCRA,  Sec.  3008(d)(3)
                                         42 U.S.C  §6928(d)(3)] and six counts knowing endangerment under RCRA, Sec  3008(e)
                                         42 U.S.C. §6928(e)].

                                        06/02/86:   Judge granted directed verdict of acquittal on one count mail fraud and
                                        five counts knowing endangerment

                                        06/17/86-   Jury returned guilty verdict on 13 counts mail fraud, one count false
                                        claim, one count failure to notify, one count mis label ing and one count of illegal
                                        disposal.

                                        08/05/86   Notice of appeal on directed verdict  filed  by government.

                                        09/16/86   Defendant sentenced to 5 years  imprisonment (all but 3 months susoeraed).
                                        4 years and 9 months probation, 1,000 hours community  service and $23,000 fine.

                                        09/23/86   Defendant filed notice of aooeal
Performance Advantage, Inc
Lyndol Bo 1 ton
84-00122

Hayes International Corporation
Louis H. Beasley
Perfomrance Advantage, Inc.
Lyndol Bolton
Ray Kelley
V. 0  Abrams
David Smith
84-00123
(M.D. Ala.)
                                        Facts.  Pollutants discharged through nose from lagoon into water by facility proces-
                                        sing waste oil and jet fuel (Performance Advantage)   Hazardous waste from company in
                                        business of removing paint from used aircraft (Hayes International) disposed of ana
                                        released without notification   Beasley is Hayes employee responsible for disposal of
                                        hazardous wastes.  Bolton is president of Performance Advantage.  Abrams operated
                                        Coosa County landfill   Kelley and Smith are residents of Coosa County, Alabama.

                                        06/28/84.  Two indictments returned.  First charged Performance Advantage and 80Iton
                                        with four counts discharge of pollutants without NPOE5 permit in violation of Clean
                                        Water Water Act, Sees. 301 and 309(c)(l) [33 U.S.C  §§1311 and  1319(c)(l)].  Second
                                        indictment charged 19 counts as follows-

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                                                                                                                 04/22/87  -  8
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED WITH
                               RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)  AUTHORITY (cont.)
Defenaant(s)/0ocket No./Court
                                 Facts and Status
Performance Advantage, Inc.
Hayes International Corporation
  (cont.)
Ray Kelley
86-189 N
(MO  Ala.)
            EPA Region IV (cont.)
     Hayes and Beasley -  Eight counts  transportation of  hazardous waste  to unper-
     mitted facility in violation  of RCRA,  Sec.  3008(d)(l)  [42  U S C   §6928(d)(l)].
     five counts storage  and/or disposal  of hazardous wastes  without  permit  in viola-
     tion of RCRA,  Sec.  3008(d)(2)(A)  [42 U.S.C.  §6928(d)(2)(A)], one count  con-
     spiracy [18 U  S.C  §371]

     Performance Advantage and Bolton  -  Eight counts violation  of RCRA,  Sec
     3008(d)(l), six counts violation  of RCRA,  Sec.  3008(d)(2)(A), one count Know-
     ing enaangerment in  violation of  RCRA, Sec.  3008(e) [42  U.S C. §6928(e)], one
     count failure  to report release of  hazardous substance under CERClA, Sec  L03(o)
     [42 U S C  §9603(b)], and one count conspiracy.

     Kelley - One count violation  of RCRA,  Sec.  3008(d)(l), four counts  violation of
     RCRA, 3008(d)(2)(A), one  count knowing endangerment in violation of RCRA, Sec
     3008(e), and one count conspiracy

     Abrams - One count under  CERCLA.  Sec  103(b), one count  under  RCRA, Sec.
     3008(d)(2), and one  count conspiracy

     Smith - One count under RCRA, Sec.  3008(d)(l) and one count  conspiracy

08/29/84   Performance Advantage and Bolton each pled guilty  to one count under  Clean
Water Act, Sees  301 and 309(c)(l) and one count under RCRA,  Sec.  3008(d)(l)

10/09/84-  Trial began against Hayes International. Beasley,  Abrams and Smith (Kelley
remained fugitive)

10/16/84:  Court entered judgment  of acquittal as to Abrams and Smith after conclu-
sion of government's case

10/17/84.  After both sides rested, Court acquitted Hayes  International  and Beasley
on five storage and disposal counts

10/19/84   Jury returned guilty verdicts against Hayes  International   and Beasley on
eight counts each of transportation to unpermitted facility under RCRA,  Sec
3008(d)(l).  Both defendants acquitted on conspiracy counts

11/15/84:  District Judge Robert Varner set aside jury  verdicts and  acquitted riayes
International and Beasley on all counts

11/26/84.  Performance Advantage sentenced to $2.500 fine  on Clean Water Act count
and $50 fine on RCRA count   Bolton sentenced to  $2,500 fine plus 5 years prooation
on Clean Water Act count and 5 years prooation on RCRA  count,  sentence  to run
concurrently

12/13/84-  Protective notice of appeal filed by  government in  Eleventh  Circuit with
respect to decision overturning jury veraicts against Hayes  International and
Beasley

06/18/85.  Government's brief  filed in Eleventh  Circuit

12/19/85:  Appeal argued  in Eleventh Circuit

04/21/86:  Reversal by Eleventh Circuit of decision  overturning jury verdict against
Hayes  International and Beasley.

06/11/86:  Hayes International  sentenced to  $2,500  fine and  Beasley  sentenced to
$1,000  fine.

Facts:  Kelley was a fugitive at the time of  the  trial.
11/25/86.  Three count indictment  filed  charging Kelley with violation  of  RCRA.
Sec. 3008(d)(2)  [42 U.S.C.] §6928(d)(2)]

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                                                                                                                 04/22/87 - 9
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED WITH
                               RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)  AUTHORITY  (cent.)
Defendant s)/0ocket No /Court
                                 Facts  and Status
Ray Kelly
  (cent.)
ABC Compounding Company, Inc
William S  Armistead
Vincent Armistead
85-484
(N D. Ga.)
James H  Hedrick
Tern .  Lori,  Chris, Inc.
84-00008
(W 0  Ky.)
James H  Hedrick
T L C , Incorporated
84-00084
(M D  Tenn )
            EPA Region IV (cont.)

03/03/87   After a 2-day trial,  the jury returned a  guilty  verdict to all three
counts of the indictment charging Ray Kelley with storage of  hazardous waste without
a RCRA permit.
George Mills                            Facts:   Storage of hazardous  waste  and  failure  to  give  required notification of
84-00165                                existence of hazardous waste  facilities  located in Nashville and Smyrna, Tennessee
(M.D. Tenn.)                            and in Semes,  Alabama.

                                        09/19/84:  Four-count indictnent  filed  in United States District Court  for Middle
                                        District of Tennessee (unsealed on  09/21/84)  charging two counts storage of hazardous
                                        waste without permit in violation of  RCRA,  Sec.  3008(d)(2)(A) [42 U.S.C.
                                        §6928(d)(2)(A)j and two counts failure  to notify of  existence of hazardous waste
                                        facility in violation of CERCLA,  Sec. 103(c)  [42 U.S.C. §9603(c)]

George Mills                            11/28/84:  One-count information  filed  in United States District Court  for Southern
84-00119                                District of Alabama charging  violation  of CERCLA,  Sec.  103(c) for failure to notify
(S D  Ala  )                             of existence of hazardous waste facility.

                                        12/11/84:  Mills entered guilty plea, under Rule 20  of  the  Federal  Rules of Criminal
                                        Procedure, in Middle District of  Tennessee  to two  counts of violation of CERCLA,
                                        Sec.  103(c) in Tennessee and  one  count  violation of  CERCLA, Sec  103(c) in Alabama.

                                        01/29/85:  Mills sentenced to 5 years probation, $30,000 fine and condition that  fui:
                                        written account of actions and recommendations  for compliance to avoid  similar con-
                                        traventions of environmental  laws be  submitted  to  professional journals in field
Facts   Company engaged in business  of  selling,  blending,  mixing and packaging chemi-
cals for use as domestic and industrial  cleaners,  solvents,  aerosols and  pesticides.
William Armistead was vice president and part owner and Vincent Ami stead,  his son,
was plant supervisor.


12/18/85.   Company waived indictment and entered guilty plea to three-count informa-
tion filed same date charging one count  conspiracy to violate RCRA [18 U.S.C. §371].
one count disposal of hazardous  waste without permit under RCRA, Sec.  3008(d)(2)(A)
[42 U.S C.  §6928(d)(2)(A)j and one count failure to notify of release of  hazardous
substance under CERCLA, Sec.  103(b)  [42  U S.C.  §9603(b)]   William Araistead and
Vincent Armistead each charged with  one  count conspiracy and one count disposal of
hazardous waste without RCRA permit  ana  eacn pled guilty to RCRA count

01/30/86:   Company sentenced to  fine totalling $40,000.  William Armistead and
Vincent Armistead each received  suspended term of imprisonment and 1 year probation,
$20,000 fine and ordered to complete cleanup of Jim's Old Plant in northwest AUan:a

Facts:   Transportation, storage  and  disposal of electric furnace emission control
dust containing lead and cadmium without permit to facilities in Kentucky and Ten-
nessee.  Tern, Lori, Chris, Inc  (T L  C ; is chemical brokerage firm with Hedncn  a
president.

05/09/84.   Three-count indictment filed in United States District Court for Western
District of Kentucky charging Hedrick and Tern, Lori, Chris, Inc. each with one
count transportation of hazardous waste to unpermitted facility in violation of  RCRA
Sec  3008(d)(l) [42 U.S.C. §6928(d)(l)], one count disposal  of hazardous  waste
without permit in violation of RCRA, Sec.  3008(d)(2)(A) [42 U.S.C. §6928(d)(2)(A)I
and one count conspiracy [18 U.S C.  §371].

05/16/84'   Indictment filed in United States District Court for Middle District  of
Tennessee charging Hedrick and TLC each with one count transportation of  hazardous
waste to unpermitted facility in violation of RCRA, Sec. 3008(d)(l) and one count
disposal of hazardous waste without permit in violation of RCRA, Sec.  3008(d)(2)(A).

07/18/84:   Hedrick pled guilty to both  counts charged in Middle District of
Tennessee.
                                        07/18/84:   Company pled guilty in Middle District of Tennessee to same counts

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                                                                                                                 04/22/87 - 10
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED WITH
                               RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) AUTHORITY (cont.)
Defendants)/Docket No. /Court
                                 Facts and Status
James H  Hedrick
  (cont.)
Alley-Cassetty Coal Company
Donald H. Draper
85-00043
(M.O. Tenn )
Alley-Cassetty Coal Company
Donald M  Draper
85-00007
(W D  Ky )
RAO Services, Inc
Author Sciullo
George Gary
86-00011
(W.D  Ky )
            EPA Region IV (cont.)
07/18/84   Hedrick and Company each entered guilty pleas to all  counts  charged  in
Western District of Kentucky.

03/14/85-   Hedrick sentenced to 1 year and 1 day imprisonment for charges  in Middle
District of Tennessee plus 3 years probation and 200 hours community service.   Com-
pany fined $5,000 for charges on same count

03/19/85:   Hedrick sentenced to 1 year and 1 day imprisonment (sentence imposed in
Tennessee served concurrently), and Company sentenced to $3,000  fine for charges in
Western District of Kentucky.

Additional Facts.   Alley-Cassetty carried out actual transportation of  emission con-
trol dust to strip mine sites.   Draper was former transportation manager.
03/25/85:  Information filed in Middle District of Tennessee charging Alley-Cassetty
and Draper with one count transportation of hazardous waste to unpermitted facility
in violation of RCRA. Sec.  3008(d)(l)

03/28/85.  Information filed in Western District of Kentucky charging Alley-Cassetty
and Draper with one count transportation of hazardous waste to unpermitted facility
in violation of RCRA, Sec  3008(d)(l).

04/01/85:  Defendants each entered guilty pleas to charges in Middle District of
Tennessee.
04/30/85:  Draper sentenced,  in Middle District of Tennessee, to 1 year and 1 day
imprisonment with all but 6 months suspended (sentence recommended to be served in
half-way house), 2 years probation and $8,000 fine (to be paid within 7 months).

05/14/85-  Defendants each entered guilty plea to charges in Western District of
Kentucky.

09/27/85.  Draper sentenced,  in Western District of Kentucky, to 1 year and 1 day
imprisonment (all but 6 months suspended) plus 2 years probation.   Incarceration
to be served concurrently with sentence imposed in Tennessee; however, Draper not ta
be allowed to serve sentence in half-way house.

09/30/85:  Alley-Cassetty sentenced, in Western District of Kentucky, to $25,000
fine   Civil penalty imposed on same date oy Tennessee State Administrative
authority.

12/09/85.  Alley-Cassetty sentenced, in Middle District of Tennessee, to $10,000
fine.

Additional facts   RAD Services engaged in chemical manufacturing and, in 1982,
stored toxic lead and cadmium emission control dust at warehouse in Bowling Green.
Sciullo  is executive vice president and Gary is head of chemical division

04/25/86:  Five-count indictment filed in Western District of Kentucky charging Com-
pany with three counts storage of hazardous waste without permit in violation of
RCRA, Sec  3008(d)(2), one count transportation of hazardous waste to unpernitted
facility in violation of RCRA, Sec. 3008(d)(l), and one count conspiracy [18 U.S C
§371]    Sciullo charged with two counts violation of RCRA, Sec. 3008(d)(2), one count
violation of RCRA, Sec. 3008(d)(l), and one count conspiracy.  Gary charged with one
count violation of RCRA, Sec. 3008(d)(2) and one count conspiracy.
                                        10/20/86:  RAO Services pled guilty to two counts of RCRA storage violations. Gary
                                                       Ione such count and
                                                   CRA storage violation.
pled guilty to one such count and Sciullo pled guilty to one count conspiracy ana
one count Rf~~
                                        12/01/86:
                                        1 year
           RAO Services was sentenced to a total fine of $75,000 to be paid within

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                                                                                                                04/22/87 - 11
                                         ENVIRONMENTAL INVESTIGATIONS  INITIATED WITH
                               RESOURCE CONSERVATION AND RECOVERY  ACT  (RCRA)  AUTHORITY  (cont.)
Defendant(s)/Docket No./Court
                                                               Facts  and  Status
RAO Services, Inc.
  (cont.)
                                          EPA  Region  IV  (cont.)
                                   Gary  -  Sentenced to 2 years  in  the  custody of the U.S  Attorney General with all
                                   but 30  days in  jail suspended,  a $10,000  fine, 200 hours of community service
                                   and 2 years of  probation

                                   Scuillo - Sentenced to  two concurrent 2-year terms of  incarceration with all but
                                   6  months suspended, a $10,000 fine,  200 hours of community service and 2 years
                                   probation
Norman F
65-00092
(M 0  Fla )
Smith
Everett 0  Harwell
Eugene Roy Baggett
  (Southeastern Waste
  Treatment, Inc
85-28
(NO  Ga )
Laurence H  Welsh
J  Welsh i Sons, Inc.
  (Barry Air Tool Supply)
83-60S43
(E.O. Mich )
Facts.   Companion case to Greer.   Fraudulent invoices  dated  July  1982  mailed  to
Florida State Department orTnvironmental  Regulation (OER)    False  reports  prepared
on laboratory chemical tests,  which had never been performed,  on  papers  bearing  name
of Environmental  Testing Laboratory,  Inc.  of Chicopee, Massachusetts,  which had  never
authorized use of its name.   Lab tests  to  have been performed in  connection with
cleanup of one of Greer's illegal  hazardous  waste dumpsites  in Sanford.   OER  had con-
tracted with Greer and Greer had sub-contracted to Smith.   11/21/85:   Indictaient
filed charging three counts  mail  fraud  [18 U S C.  §1341].

01/08/86-   Defendant entered guilty plea to  one count mail  fraud.

07/21/86   Defendant sentenced to $1,000 fine. 4 years probation  and restitution of
$5,420	

Facts   President (Harwell)  and vice president for operations (Baggett)  of waste
treatment company disposed of electroplating wastes without permit, filed false
statements with Gerogia Environmental  Protection Division.   Defendants also trans-
ported hazardous wastes, failed to notify of their release,  misrepresented that
wastes had been incinerated and poured  them  into city sewage system.

12/10/85.   15-count indictment returned (sealed until defendants  could be arrested an
12/11/85)   Harwell and Baggett charged with one count conspiracy to violate  18
U S C  §1001 and RCRA [18 U S C.  §371], four counts making false  statements [18
U S.C  §1001], one count treatment and  disposal of hazardous waste without permit
under RCRA, Sec  3008(d)(2)(A) [42 U S  C  §6928(d)(2)(A)],  one count transportation
of hazardous wastes to unpermitted facility  under RCRA, Sec. 3008(d)(l)  [42 U.S.C.
§6928(d)(l)] and one count storage of hazardous waste without permit under RCRA. Sec.

3008(d)(2)(A) [42 U.S C  §6928(d)(2)(A)]   Harwell also charged with one additional
transportation count and one additional storage count   Baggett also charged with two
additional transportation counts, two additional disposal counts  and one count fail-
ure to notify of release of nazardous substance under CERCLA, Sec.  103(b) [42 U.S.C.
§9603(b)].

10/29/86   Defendants each pled guilty to one  felony count of treating and disoosing
of hazardous (electroplating) wastes without a permit, in violation of Sec
3008(d)(2) of RCRA.  Harwell also pled guilty  to one  18 U S C  §1001 false statement
felony count   Baggett also pled guilty to a RCRA unpermitted transportation of hai-
ardous waste felony count in violation of 42 U S C. §6928(d)(l)

10/05/87   Harwell sentenced to 3 years imonsonment  and $20,000 fine   Baggett sen-
tenced to  18 months imprisonment and $10.000 fine

                EPA Region V

Facts   Hazardous waste consisting of discarded paint, varnish and other  ignitabie
substances stored without permit and transported to unpermitted facility   Laurence
is president and operator of Company in the panning lot maintenance business.


09/21/83:  Four-count  information  filed charging each defendant with one count  stor-
age of hazardous waste  in violation of RCRA,  Sec. 3008(d)(2)(A) [42 U.S.C.
§6928(d)(2)(A)] and one count  transportation of hazardous wazste to unpermitted
facility of violation  of RCRA, Sec. 3008(d)(l) [42  U.S.C. §6928(d)(l)]

10/05/83:  Both defendants pled guilty to all  charges.

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                                                                                                                04/22/87 - 12
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED  WITH
                               RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)  AUTHORITY  (cont.)
Oefendant(s)/Docket No /Court
                                 Facts  and Status
Laurence M  Welsh
  (cont )
            EPA Region V (cont.)
12/13/83:   Welsh sentenced to 2 years imprisonment (all  but  4 months suspended) and
2 years probation.   Company sentenced to SI.000 fine
John Van Hoesen
  (QuVoe Chemical Industries, Inc.
84-00838
(N D  111 )
John Suerth
84-00840
(N 0  111 )
Executive Advertising, Inc
Thomas David laViolette
Roderick Warren Reiser
85-80795
(E D  Mich )
Charles j  Berlin
85-50057
(£ 0  Mien )
Facts:   150,000 gallons of spent halogenated solvent  handled without oermit at chemi-
cal recycling facilities in Schiller Park and Oes  Plains  and false  statements mace ta
EPA claiming exemption from regulations.   Van Hoesen  is managerial  employee   Suerth
is president.

11/15/84   Information filed charging Van Hoesen with one misdemeanor  count for con-
cealing records under RCRA, Sec  3008(d)(4)  [42  U  S.C.  §6928(d)(4)]   Separate
indictment filed against Suerth charging  11  counts transportation of hazardous waste
to unpermitted facility under RCRA.  Sec.  3008(d)(l) [42 U S.C.  §6928(d)(D],  two
counts treatment, storage and disposal  of hazardous waste without permit  under RCRA,
Sec.  3008(d)(2) [42 U S.C.  §6928(d)(2)].  and one count false statements  [18
U S C  §1001]

11/23/84.   Van Hoesen pled guilty to one  RCRA count

11/29/84   Superseding indictment filed charging Suerth with same  substantive
charges.

01/16/85   Van Hoesen sentences to 3 years probation  plus $4,000 fine  and 300 hours
community service.

03/25/85   Suerth pled guilty to suoerseding information  filed on  same date charging
two counts concealment of required records under RCRA, Sec.  3008(d)(4)

05/24/85   Suerth sentenced to 9 months imprisonment  plus 5 years  probation and
S25.000 fine

Facts.   Approximately 100 drums containing waste inks and lacquers  found in  abandoned
warehouse in Detroit   LaViolette was Company president and part owner   Reiser  -as
Company vice president and part owner

11/20/85:   Three-count indictment filed against Comoany,  LaViolette and Reiser cnarg-
ing one count transportation of hazardous waste to unpermitted facility under SCRA,
Sec  3008(d)(l) [42 U S.C.  §6928(d)(l)],  one count treatment,  storage  and disposal  af
hazardous waste without permit under RCRA. Sec.  300S(d)(2)(A)  [42  U S  C
§6928(d)(2)(A)]. and one count conspiracy to violate RCRA [18  U.S  C  §371]

01/23/86:   Company, LaViolette and Reiser eacn entered guilty  plea to  one count  of
knowingly transporting hazardous waste to unpermitted facility in violation of
RCRA, Sec. 3008(d)(l)

04/25/86:   Company sentenced to $50,000 fine   Each  individual sentenced to 2 years
imprisonment (all but 60 days suspended), 3  years probation. 400 hours community
service and SIS,000 fine

Facts  Burial of five underground storage tanks containing C-56 and other combounds.
hundreds of barrels containing paints, acids and cyanide; plus paint sludges  dumoed
into covered earthern trench, all prior to enactment of  RCRA at largest Superfund
site in Swartz Creek. Michigan   Berlin  is president and owner/operator of Farro
Liquid  Incineration,  Inc.

11/06/85:   One count  indictment filed charging failure to notify of hazardous waste
facility  in violation of CERCLA, Sec  103(c) [42 U S.C.  §9603(0].

11/08/85-   Superseding  indictment filed charging same count

01/16/86:   Defense notion  for directed verdict of  acquittal granted on ground that
Government failed to  prove  specific  knowledge of defendant

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                                                                                                                 04/22/87 -
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED WITH
                               RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) AUTHORITY (cont.)
Defendant s)/0ocket No. /Court
                                 Facts and Status
Richard M  Minis
  (Brass Mill Co.)
85-252
(N D  Tex.)
Arneson Timber Company, Inc
86-00097
(E 0  Mo.)
Layton Brotners Drum Company, Inc
Willie Frank Mines
85-00174
(0  Colo )
Eagle Picner Industries, Inc.
35-343
Richard Brown
86-005
(0  Colo )
                EPA Region VI

Facts.  Former president of brass plating company directed employees  to dump  dozen
55-gallon drums of toluene at L.  B.  Houston Nature Area.

08/20/85:   One-count indictment filed charging defendant  with disposal  of  hazardous
waste without permit in violation of RCRA, Sec.  3008(d)(2) [42 U S.C   §6928(d)(2)].

08/28/85:   Defendant pled guilty

09/25/85.   Defendant sentenced to 2  years probation and $2,500 fine payable either in
lump sum or monthly installments

               EPA Region VII
Facts   Contents of tank containing  pentachlorophenol  dumped into catch basin at
steel mill facility in Steelville

04/21/86-   Information filed charging Company with one count failure  to notify of
release of hazardous substance in violation of CERCLA, Sec.  103(b) [42 U.S.C.
§9603(b)]

04/29/86-   Company pled guilty and sentenced to $7,500 fine ($3,500 stayed)  plus S25
special assessment and 2 years probation.

               EPA Region VIII
Facts   Storage and disposal of hazardous waste without permit, and transportation af
hazardous waste via interstate highway 1-70 through Eisenhower Tunnel without mani-
fests   Oils and other liquid refuse matter channeled via earth trench into  Ralston
Creek without permit.   Hines was  Company manager.

05/23/85   11-count indictment filed charging Company with three counts disposal of
hazardous waste without permit and four counts storage of hazardous waste wunout
permit, all in violation of RCRA. Sec.  3008(d)(2) [42 U S C. §6928(d)(2)], one count
false statements [18 U S C  §1001],  one count violation of the Refuse Act [33 U S C.
§407], and one count violation of the Hazardous Materials Transportation Act (HMTA)
[49 U.S.C  §1809].   Mines cnarged with one count false statements
                                        07/12/85:
                                        counts.
           Superseding information filed against same defendants charging same
09/12/85   Company entered guilty plea to one count violation of Refuse Act and one
count violation of HMTA.   Charges against Mines dismissed

10/24/85:   Company sentenced to $10,000 fine on HMTA count and $2,000 fine for Refuse
Act violation.

Facts   Nickel-cadmium battery manufacturer's environmental engineer (Brown) ordered
burial of five drums of toxic wastes without permit   During removal of drums, con-
taminated sand spilled onto soil and remained unreported

12/11/85.   Company pled guilty to one-count information filed same date charging
failure to notify of release of hazardous substance in violation of CERCLA, Sec.
103(b) [42 U S C. §9603(6)]

01/09/86:   Two-count indictment filed charging Brown with one count disposal of Haz-
ardous waste without permit under RCRA, Sec  3008(d)(2)(A) [42 U S C  §6928(d)(2)(A).
and one count making false statements to EPA [18 U.S C. §1001].

01/29/86:   Company sentenced to $3,500 fine.

03/31/86:   Court dismissed false statements count against Brown and placed him in
pretnal diversion program.

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                                                                                                                 04/22/87 -  L*
                                         ENVIRONMENTAL INVESTIGATIONS  INITIATED  WITH
                               RESOURCE CONSERVATION AND RECOVERY  ACT  (RCRA)  AUTHORITY (cont.)
Defendant(s)/Docket No /Court
Jay Hamburg
  (Metro Shop Supplies)
86-174
(0  Colo )
Neil Moser
36-199
(0  Colo )
Keeoler Corporation
86-104
(0  Colo )
John Micnael Nelson
06-122
(0  Colo )
                                                                         Facts  and Status
                                                   EPA Region VIII  (cont.)
                                        Facts   Transportation of used  paint  solvents  and  paint waste  including acetone,
                                        methyl  ethyl  ketone,  toluene, xylene  and  N-butyl acetate  to Denver  facility.  Hamburg
                                        is president  and Moser is vice  president

                                        06/17/86:   Five-count indictment  returned charging one count treating  hazardous wastes
                                        without permit in violation of  RCRA,  Sec   3008(d)(2)(A) [42 U  S C.  §6928(d)(2)(A)l.
                                        two counts storing hazardous wastes without  permit in violation of  RCRA, Sec
                                        3008(d)(2)(A), one count disposing hazardous waste without permit  in violation of
                                        RCRA, Sec   3008(d)(2)(A) and one  count  making  false statements to  EPA  [18 U.S C.
                                        §1001].

                                        07/22/86   Information filed charging Moser  with one count failure  to  report release
                                        of hazardous  substances under CERCLA. Sec.  103(b)  [42 U S.C. §9603(b)]

                                        07/31/86-   Moser pled guilty to information

                                        09/10/86-   Moser sentenced  to a $500  fine,  2 years of probation,  a $25 assessment  for
                                        the Crime  Victims fund and  ordered to perform  200  hours of community service.

                                        10/30/86   Hamburg pled guilty  to the two-count information  charging him with  viola-
                                        tion of CERCLA reporting requirements [42 U.S  C. §9603(b)(3)]  which had been  filea
                                        the previous  day

                                        12/12/86   Hamburg sentenced to $2,000  fine, 2 years of  probation and 120 hours  of
                                        community  service   He must also  attend a course on hazardous  waste.

Frankel Manufacturing Company
85-224
(0  Colo )
                                        Facts   Storage of hazardous  waste  without  permit  in  excess  of  1,000 kilograms.

                                        07/17/85-   Company waived  indictment  and  entered plea of guilty to information  filed.
                                        on same date charging one  count  violation of  RCRA.  Sec  3008(d)(2) [42 U  S  C
                                        §6928(d)(2)]

                                        08/30/85   Company sentenced  to  $200.000  fine and  3 years probation   First $100.000
                                        payable in two annual installments  beginning  08/30/86   Remaining $100,000  suspended
                                        if terms of probation,  including cleanup  and  $200  assessment to Crime Victims Funa
                                        are met

                                        Facts.   Methylene chloride and tetrachloroethene  released without notice

                                        04/15/86-   Company entered guilty plea to information filed  same date charaing one
                                        count failure to notify of release  of hazardous suostance in violation of CERCLA.
                                        Sec. 103(b) [42 U.S C  §9603(b)]

                                        05/30/86   Company sentenced  to $5,000 fine ($4,000 suspended)  and 6 months probation
                                        during which time cleanup  is  required, plus $100  to Crime Victims Fund   State of
                                        Colorado collected $22.500 civil penalty  and issued administrative order  for cleanup.

                                        Facts   Abandonment of spent  solvents and paint sludges at self-storage facility ;n
                                        Broomfield, Colorado

                                        04/25/86-   Indictment filed charging defendant with 2 counts knowing storage andr
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                                                                                                                04/22/87 - 15
                                         ENVIRONMENTAL  INVESTIGATIONS  INITIATED WITH
                               RESOURCE CONSERVATION AND  RECOVERY ACT  (RCRA) AUTHORITY (cont.)
Oefendant(s)/0ocket No /Court
                                              Facts and Status
Neville Chemical  Company
  (cont )
                        One-count indictment returned against Company charging  knowing  disposal  of
             hazardous wastes without permit in violation of RCRA,  Sec  3008(d)(2)(A) [42  U  S  C.
01/29/86
hazardou
§6928(d)(2)(A)]

09/30/86-   One week trial  to the court began.
                                        10/07/86.   Defendant  found guilty  as charged.

                                        11/24/86.   Defendant  sentenced  to  pay $50,000 fine ($10,000 supsended if paid by
                                        January 15,  1987)  and placed  on probation  for 3 years
Frontier Fertilizer Company
B&R Company of Davis
Dennis Kidwell
86-057
(E.O.  Cal )
Oarrel A  Duisen
George W  Shearer
Glen 0  Faulks
RogelioA  Mann-Sagristo
U S  Technology and Disposal
  Service, Inc
Tratamientos Petroquimilos
Mexicanos. S A. de C.V
Guillermo Marin-Orosco
86-0401
(S.D  Cal )
 Pacific Hide & Fur Depot,
 William Kmck
 Jerry Graham
 83-40028
 (0   Ida.)
             Facts.  Rinsates from holding tanks and chemical  applicators dumped into unlinea  pits
             by agricultural chemical distributor (B&R), its successor company (Frontier)  and  man-
             ager of both operations (Kidwell)

             11/14/85   Indictment lodged with clerk of the court.

             03/19/86.  Upon waiver of indictment, defendants pled guilty to five-count informa-
             tion filed on same date charging B&R with two counts storage and disposa  of hazard-
             ous wastes at unpermitted facility in violation of RCRA, Sec. 3008(d)(2)(A) [42
             U S C  §6928(d)(2)(A)] for its 1981 and 1982 disposal practices.  Frontier pled
             guilty to same charges for its 1983 and 1984 disposal practices, and Kidwe 1 with one
             count of same charge.  Two companies each sentenced to $75,000 fine pjus cleanup of
             site

             06/11/86   Kidwell sentenced to 2 years imprisonment (all but 180 days  suspended).
             5 years probation and $10,000 fine to be paid from personal  funds.

             Facts-  Hazardous waste disposal corporation in Beiate, California (U.S  Technology)
             designated as exclusive reoresentative of Mexican corporation established to operate
             Rancho Ramo recovery and recycling facility (Tratamientos)   Charges resulted from
             export of hazardous waste for disposal in Mexico   Ouisen was owner and corporate
             officer of Tratamientos and chief executive officer of U S   Technology   Shearer was
             president, chairman of the board and principal owner of U S  Technology, and Faulks
             was Company vice president   Mann-Sagnsto was manager of Tratamientos

             04/18/86-  Each defendant charged oy indictment (unsealed 04/22/86) with one count
             conspiracy [18 U S C  §371], seven counts mail fraud [18 U S C  §1341]  and 33 counts
             utilizing false documents [18 U S C  §1001] resulting  from export of hazardous waste
             for disposal  in Mexico

             08/14/86:  Guillermo Marin-Orosco was added to the  indictment for the same charges

             10/28/86:  Mann-Sagristo pled guilty to one count  of  conspiracy

             11/01/86:  Trial begins.

             11/19/86   Shearer and Duisen pled guilty  to  two  counts  of  making  false statements
             and Faulks pled guilty to one count  of maKing  false statements

             03/87    Shearer was  sentenced to pay a $24,000  fine,  serve  120  days of  a 4-year  cerm
             of  imprisonment ana  provide  400  hours of community  service  and  placed on probation
             for 5 years    Duisen was  sentenced to pay  a $24.000 fine,  serve  120 days of  a  3-yea-
             term  of  imprisonment and  provide 400 hours of  community  service  and placed  on  orooa-
             tion  for  5 years   Faulks was sentenced  to pay a  $12,000 fine and  placed on  proba-
             tion  for  5 years.  Marin-Sagristo  was  sentenced  to  pay a $5,000  fine and placed  :n
             probation  for 5 years.

                             EPA  Region  X
Inc          Facts.   Hundreds  of  PCB  capacitors and  PCB liquids  from transformers dumped into o;c
             adjacent  to  defendants'  scrap metal  salvaging facility in Pocatello.  William
             manages  this  facility.

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                                                                                                                 04/22/87  - 16
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED WITH
                               RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) AUTHORITY (cont.)
Oefendant(s)/0ocket No /Court
                                                                         Facts and Status
                                                    EPA Region X (cont.)

                                        10/12/83:   Five-count indictment returned (unsealed on 10/17/83)  against Conpany and
                                                       	«__	  ._.k._.__j__ ^^__ BK. . m^ft if M « ^i* Ljt +h Ann ^miftt  i mn^nnAp Hi cnncAl
Pacific Hide & Fur Depot, Inc.
  (cont )
Richard Allen Taggert
Keith Egan
  (Evans Transportation Company)
85-60016
(0  Or )
Peter Heaegard
Eric Myers
JANCO United,  Inc
85-00342
(W  D  '>iash  )
^y/ 1£/ QJ   rlVCWUUIIl I IIU i w MUCH fc ' « VMI IIKM ^WII«*(«BIW ••• ••• _ - > »— /  v V . .._ — _ ——r	j  — —
two corporate employees,  charging Conpany and Kmck with one count improper  disposal
of PCB capacitors, one count improper disposal of PCBs, one count failure to properly
mark PCB containers, and one count of failure to maintain required records concerning
PCB items, all in violation of TSCA [15 U.S.C. §§2614 and 2615(b)], and  one  count_
                                        r\,9 1 I CUl 9 ,  Oil  I " » i W »BV1wn wi  • wwn i*w **.«.«•  j j--- •   ^~_TT»~'*»  ^/*i/t"\f.-,,  -  y»
                                        failure to  report release of hazardous substance under CERCLA,  Sec.  103(6)  [42  U.i.C.
                                        §9603(b)].   Graham charged with one count unlawful  disposal  of  PCBs  under TSCA  and
                                        one count failure to report release of hazardous substance under CERCLA.

                                        04/16/84   Following denial of defense motions, jury trial began.

                                        05/03/84-  After 10 days of trial, one TSCA PCB disposal count and the CERCLA count
                                        were dismissed   These were only counts in which Graham was charged.

                                        05/04/84.  Guilty verdicts returned against both Company and Kmck on three remaining
                                        TSCA counts

                                        06/29/84.  Company sentenced to $24,000 fine ($8,000 on each of three counts).   Hoick
                                        sentenced to $3,000 fine ($1,000 on each count).

                                        03/07/85:  Appeal argued in Ninth Circuit

                                        08/15/85.  Ninth Circuit reversed convictions of both defendants on ground that jury
                                        instruction on deliberate avoidance given under United  States v. Jewell was improper.

                                        12/26/85   Ninth Circuit denied government's petition for Bearing.	

                                        Facts-   False statements made to state of Oregon inspector concerning accumulation of
                                        hazardous wastes   Egan was plant manager and Taggert was plant supenntendant.

                                        04/24/85.  One-count information charging both  defendants with one  count  false
                                        statements under RCRA, Sec. 3008(d)(3) [42 U S.C   §6928(d)(3)]

                                        04/30/85:  Egan pled guilty to aiding  and abetting making false statements under
                                        RCRA

                                        05/07/85:  Taggert pled guilty to making  false  statements under RCRA.

                                        06/04/85.  Egan and  Taggert each  sentenced  to  $2,500  fine

                                        Facts-   Manufacturer of  industrial  cleaning  products  in Seattle discharged pollutants
                                         including  soaps, detergents, caustic  alkali, acids, waxes,  dyes and solvent  materials
                                        (including alcohol,  butyl  carbitol, also  known as  diethylene glycol  monobutyl  ether.
                                        xylene and mineral  soirits)  for  10  days  from manufacturing  operations  into hidden
                                        pipe  connected to  storm  sewer  leading into  Ouwamish River  Hedegard was Company
                                        president  and Myers  was  vice president.

                                         12/09/85  Two-count information filed charging Company with  one  count discharge of
                                        pollutants without permit in  violation of Clean Water Act,  Sees   301 and 309(c)(L]
                                         [33 U S C  §§1311  and  1319(c)(l)]

                                        Hedegard and Meyers  each charged with one count violation of  Clean Water Act.  Sees.
                                         301 and 309(c)(l)  and  one misdemeanor count conspiracy to violate Clean water Act
                                         [18 U.S C   §371].

                                         12/11/85:  All  defendants pled guilty to all charges.

                                         01/16/86:   Company fined $100.000 (all but $30.000 suspended  and allowance for
                                         dollar-for-dollar reduction for money spent on approved environmental or conservatio
                                         programs)  plus  facility listed on EPA List of  Violating Facilities pursuant to *0 CF
                                         Part  15 20 and  excluded from Federal  Government contracts, grants or loans.   Hedegar
                                         and Meyers each sentenced to 1 year imprisonment  (all but 5 days suspended), 3 years
                                         probation   $25  000 fine (all but $5.000 suspended) and 300 hours community service.

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                                                                                                                 04/22/87 - 1
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED WITH
                               RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) AUTHORITY (cont )
 Defendant s)/Docket No./Court
                                 Pacts and Status
 Douglas G  Hoflin
   (City of Ocean Shores)
 85-82
 (W.O  Wash )
Robert K  Blackstone
86-00012
Wendall Wayne Johnson
86-00013
(W 0. Wash )
Daniel Lee Turner
8S-332-1
(E 0  Wash )
            EPA Region X (cont.)

Facts.  Former city public works director buried 14 drums of old road striping paint
at City's sewage treatment plant adjacent to National  Wildlife Refuge in sandy soil
next to ocean, and dumped 3,500 gallons of raw sewage into sandy depression,  also
next to ocean.

10/10/85   Three-count indictment filed charging defendant with one count consoiracy
to violate RCRA [18 U.S.C.  §371]  one count disposal of hazardous waste without per-
mit under RCRA. Sec.  3008(d)(2) [42 U S.C.  §6928(d)(2)]. and one count burial  of raw
sewage in violation of sewage treatment plant permit under Clean Water Act,  Sees.
301 and 309(c)(l) [33 U S.C.  §§1311 and 1319(c)(l)].
                                        02/24/86   After 5 days of trial, jury returned guilty verdict.
                                        of one RCRA count and one Clean Water Act count
                                                                 Defendant convicted
03/28/36   Defendant sentenced to 2 years probation and 200 hours community service

Facts   Operator of auto repair facility in Federal Way (Blackstone) and independent
scrap metal dealer (Johnson) disposed of eight barrels containing paint waste and
lacquer thinner on vacant lot in Puyallup.

02/12/86:   Five-count indictment filed charging Blackstone with one count conspiracy
to violate RCRA [18 U.S C.  §371], two counts knowing transportation*of hazardous
waste without manifest in violation of RCRA. Sec  3008(d)(5) [42 U S.C. §692S(d)(5)
and two counts Knowing illegal disposal  of hazardous wastes under RCRA, Sec
3008(d)(2)(A) [42 U S C  §6928(d)(2)(A)]   Separate indictment filed same date charg-
ing Johnson with same counts

04/04/86   Johnson pled guilty to one count disposal without permit under RCRA,
Sec  3008(d)(2)(A)

01/25/86   Blackstone pled guilty to one count disposal without permit under RCRA.
Sec  3008(d)(2)(A)

05/16/86.   Johnson sentenced to 3 years  imprisonment (all but 6 months suspended),
SSOO fine, 3 years probation including condition that he participate in alconol
treatment program and $50 mandatory penalty assessment to Crime Victims Fund

06/05/86   Blackstone sentenced to imprisonment for term of 1 year and 1 day, S5.000
fine and $7,100 restitution to Washington State Department of Ecology plus S50 manda-
tory penalty assessment to Crime Victims Fund

Facts-   In May 1986, waste "restricted-use" pesticides, including paratnion, linaane,
strychnine, endrin, dieldrin and 2,4,5-T, were dumped along and into the Okanogan
River near Malott, Washington   Turner is a certified pesticide applicator

11/17/86   Eight-count indictment filed  charging defendant with six counts disoosal
of hazardous waste without a permit in violation of RCRA. Sec  3008 [42 U S C
§6928(d)(2)(A)], one count knowing endangerment by disposing of hazardous wastes wit.'
the knowledge that it placed another person in imminent danger of death or serious
boaily injury in violation of RCRA. Sec   3008 [42 U.S C. §6928(e)], and one count
failure to notify of the release of a hazardous substance into the environment  in
violation of CERCLA, Sec. 103(b) [42 U S C  §9603(b)].

03/27/87   The jury returned a verdict of acquittal to all eight counts charged
against Turner

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                                                                                                                 04/22/87  -  i£
                                         ENVIRONMENTAL INVESTIGATIONS INITIATED WITH
                               RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)  AUTHORITY  (cont.)
Defendant(s)/0ocket No /Court                                            Facts  and Status

                                          EPA-NEIC Nationally Managed Investigation

Jack E  White                           Facts:   The Food and Drug Administration discovered contamination  of  dairy products
Brownie C  McBride                      with heptachlor, a carcinogenic pesticide.   J.E.w., Inc.  succeeded White  Flame Fuels.
Jerry L  Findley                        Inc  in manufacturing fuel grade alcohol and producing animal  feed by blending spent
Henry R. White                          distillers mash with other grain and grain by-products.   Valley  Feeds.  Inc   sold tnat
86-20015                                animal  feed to livestock growers in Arkansas, Oklahoma and  Missouri   Jack E. White
(W D  Ark )                             is principal  officer, stockholder and manager of White Flame  Fuels,  Inc., JEW.
                                        [nc  and valley Feeds, Inc.,  Brownie C   McBride is  plant  superintendent employed oy
                                        White Flame Fuels, Inc., J E  W , Inc and Valley Feeds,  Inc.,  Jerry  L  Findley  is
                                        former  president of Valley Feeds. Inc.  and operations  manager of J.E.W  ,  Inc., ana
                                        Henry R  White is a corporate officer of Valley Feeds, Inc

                                        11/21/86.   52-count indictment resulted from use of seed  treated with aldrin, captan.
                                        dieldrin,  heptachlor or methoxychlor and grain contaminated with aflatoxin  to manu-
                                        facture alcohol and then mixing the adulterated or  contaminated  mash with animal  feec
                                        tnat was sold to dairy farmers.

                                        Specific charges are as follows:

                                             J   White and McBride - one count conspiracy [18 U.S.C. §371], eight counts  mail
                                             fraud [18 U S.C. §1341], 13 counts wire fraud  [18 U  S.C.  §1343], one count  rac<-
                                             eteering  [18 U.S.C.  §1962(c)], five counts interstate transportation of money
                                             taken by fraud [18 U.S.C. §2314],  six counts  adulterating food" [21 U.S C
                                             §§331(d) and 333(b)l, 11 counts interstate sales  of  adulterated food [12 U  S  C.
                                             §§331(a) and 333(b)J, and four counts discharging pollutants  in violation  of
                                             Clean Water Act. Sees  301 and 309 [33 U S C   §§1311(a)  and 1319(c)(l ]   White
                                             also charged with one count making a false statement [18 U S  C  §1001].

                                             Findley - One count conspiracy, two counts false statements,  one count mail
                                             fraud, three counts wire fraud, one count racketeering,  one count  interstate
                                             transportation of money  taken oy fraud and one count discharging pollutants.

                                             H  White • Seven counts  mail fraud, 10 counts wire fraud, one count racketeer-
                                             ing, four counts interstate transportation of money taken by  fraud, six counts
                                             adulterating food and 11 counts interstate sales of adulterated food

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                                 SECTION II

                            Clean Air Act (CAA)


Clean Air Act (CAA) 	42 USC SS 7401-7642
                                                       PL 95-95
                                                       PL 91-604

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                                                                                                                04/22/87 - 1
                                         ENVIRONMENTAL INVESTIGATION  INITIATED WITH
                                                CLEAN AIR  ACT  (CAA) AUTHORITY
Defendant s)/0ocket No /Court
                                                                         Facts  and  Status
                                                        EPA Region  I

                                        Facts.   Building demolition at Old  Pin  Shop  in Oakville without notice to EPA, with-
                                        out removing asbestos  prior to demolition  and without wetting asbestos material
                                        exposed during operation.   Vileisis is  president of Company and Fabiani is owner of
                                        Old Pin Shop.
Peter J.  Vileisis, Jr
Maurice Fabiani
Waterbury House Wrecking Co.,  Inc.
N-85-46
(D  Conn.)
Hope Resource Recovery,
36-00458
(E 0. N Y )
Alan M  Franko
  (AMF Insulation Co )
85-1146-M
(ED  va )
 Irwin  Pearlman
 Salvatore C  Williams
 86-246
 (WO   Pa  )
                                        08/01/85-   Five-count indictment filed charging  Company  and Vileisis with three
                                        counts causing asbestos emissions in violation of  Clean  Air Act,  Sees   113(c)(l)(C)
                                        112(c)(l)(B) and 112(e)(5) [42 U S.C.  §§7413(c)(l)(C), 7412(c)(l)(B) and 7412(e)(5)}
                                        and of 40 CFR 61.146, and Fabiani with two counts  of  same  Clean Air Act violations.

                                        11/04/85:   Vileisis pled guilty to one count superseding information  filed  same date
                                        charging failure to remove asbestos prior to commencement  of  demolition in  violation
                                        of Clean Air Act, Sees. 113(c)(l)(C),  112 (c)(l)(B) and  112(e)(5) and  40 CFR  §61.147.

                                        11/05/85-   Fabiani pled guilty to same charge in one-count superseding information
                                        filed this date.

                                        12/19/85:   Vileisis sentenced to 1 year suspended sentence,  5 years  probation,
                                        $25,000 fine plus $25 penalty assessment. 1,000  hours community service and must
                                        attend, at own expense, seminars on disposal of  asbestos.   Fabiani sentenced to  1
                                        year imprisonment (all but 30 days suspended),  5 years probation, $25,000  fine plus
                                        $25 penalty assessment and 1,000 hours community service.

                                        12/23/85   Charges dismissed against Company

                                        05/05/86.   Old Pin Shop and Waterbury House Wrecking each placed on EPA's  List of
                                        Violating Facilities under 40 CFR Part 15 resulting in ineligibility for EPA con-
                                        tracts, grants and loans                                              		

                                                        EPA Region II
                        inc             Air contamination source operated by refuse-incineration company  in Long Island City.
                                        Queens witnout certification required unaer State  Implementation Plan  (SIP)
                                        regulations

                                        07/02/86-   Information filed charging Company with seven counts violating Clean Air
                                        Act, Sec.  113(c)(l)(a)(ii) [42 U § C  §7413(c)(l)(a)(ii)]

                                        07/07/86:   Company pled guilty to one count operating air contamination equipment
                                        without valid certification

                                        09/10/86:  Corporation sentenced to a $10,000 fine.


                                                        EPA Region III
                                        Facts.  Failure  to notify proper U S. Government  Agency prior to  removal of  asoestos
                                        material while  fulfilling Department of  Navy contract awarded for removal and cis-
                                        posal of asbestos pipe insulation at Naval  Observatory  in Washington,  O.C    Defendant.
                                        is  former vice  president  and project manager

                                        10/31/85   Defendant  pled guilty to one  count information filed  same  date charging
                                        failure to  report  release of hazardous substance  (asoestos)  in violation of  CERCLA,
                                        Sec   103(b)  [42 U  S  C §9603(b)]

                                        12/02/85    Defendant  sentenced  to  30 days  suspended  sentence plus 6 months probation
                                        and $150  fine

                                        Facts.  Williams,  owner  of  former  school  building in  residential  area of Pittsburgn
                                        and Pearlman, contractor who  removed boiler and heating system,  failed to  comply  *itn
                                        NESHAPS work practice standards  for asbestos.   Violations include failure  to give
                                        notice of  intentions  to  demolish or renovate and  failure  to  wet  down  material ana
                                        comply with  other removal procedures  for asbestos   Violations occurred after EPA
                                        Region III  issued administrative order directing  defendants  to cease  asbestos removal
                                        work  at site and respond to requests  for information regarding these  activities.

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                                                                                                                 04/22/87 - 2
                                         ENVIRONMENTAL INVESTIGATION INITIATED WITH
                                            CLEAN AIR ACT (CAA)  AUTHORITY (cont.)
Defendant s)/0ocket No /Court
                                 Facts  and Status
                                                   EPA Region III  (cont.)
Irwm Pearl man                          10/31/86:   Indictment filed charging  each  defendant with  two counts failure to conr
  (cont )                               ply with NESHAPS standards in  violation  of Clean Air Act, Sees. 112(c) and
                                        113(c)(l)(C) [42 U S.C.  §§7412{c)  and 7413(c)(l)(O] and  one count failure to comply
                                        witn EPA administrative  order  in violation of Clean Air Act, Sec. 113(c)(l)(B)
                                        [42 U.S C.  7413(c)(l)(B)].

                                        12/30/86-   Defendants pled guilty  to  two counts of violating NESHAPS standards and
                                        each sentenced to $1,000 fine
Norbert Emel Gall
Dennis Ray Alston
Phillip Anthony Williams
Brigitte Gertrud Laurus
  (Fred Fincher Motors, Inc
85-236
(S D  Tex )
Norbert Emel Gall
Freddie Lee Fincher, Sr
Donald Lee Fincher
Bngitte Gertrud Laurus
85-00278
Brigitte Gertrud Laurus
Edward F  Wiatt
H86-278
(S 0  Tex )
                EPA Region VI
Facts   Automobile broker and  associates imported cars  from Germany and deceived EPA
into granting "5-year old exemption"  of nonconforming vehicles  from Clean Air Act
requirements   Freddie Fincher was  principal  stockholder and Company president.   Don-
ald Fincher was general manager and executive vice president.   Alston was owner  of
D R A  Construction Company and Williams was  Alston's employee.

10/04/85:   31-count indictment filed  charging Gall. Alston and  Williams each with one
count conspiracy [18 U.S C  §371],  10 counts  entering goods into country by means of
false statements [18 U.S C.  §542],  10 counts  smuggling [18 U.S.C.  §545], and 10
counts false statements to EPA and  Customs Service [18 U.S.C.  §1001],  Laurus charge!
with one count conspiracy

11/26/85-   47-count indictment filed  charging Freddie Fincher and Donald Fincher eacn
with one count conspiracy [18  U S C  §3711. 17 counts entering  goods into country by
means of flase statements [18  U S.C  §542], 12 counts smuggling [18 U.S.C.  §545] and
17 counts false statements to  EPA and Customs Service [18 U.S.C.  §1001].  Laurus
charged with one count conspiracy,  one count  false statements and two counts
smuggling

12/04/85.   Williams pled guilty to  one count  conspiracy [18 U S C.  §371] ana three
counts smuggling [18 U.S C  §545]

01/28/86-   Superseding information  filed charging Laurus with one count false state-
ments under the Clean Air Act, Sec. 113(c)(2) [42 U.S.C  §7413(c)(2)]

02/06/86:   Gall entered guilty plea under first indictment to one count conspiracy
[18 U.S C  §371] and six counts entry of goods by way of false  statements [18 U  S C.
§542].

02/14/86:   Gall entered guilty plea under second  indictment to  one count conspiracy.
four counts entering goods by  means of false  statements and five counts smuggling.

03/25/86:   Laurus pled guilty  to one count under Clean Air Act. Sec  113(c)(2)

04/17/86-   Freddie Fincher and Donald Fincher each pled guilty to one count entry of
goods into country by  false statements [18 U S C. §545]

05/27/86   Freddie Fincher and Donald Fincher each fined $10,000

07/10/86   Laurus sentenced to 1 year probation.

Facts   Co-owner of Grand Prix Motors imported foreign automobiles under a "5-year-
old exemption" obtained  from EPA

10/10/86:   Information  filed charging Wiatt with  10  counts of submitting fraudulent
documents to EPA in violation of Clean Air Act, Sec. 113(c)(2) [42 U S.C.
§7413(c)(2)]
                                                                      to a single felony count of conspiracy to violate
                                                                      and 10 misdemeanor counts under Sec. 113(c)(2) of M
10/14/86.  Alston pled
18 U.S.C. §§542, 545 and 100L 	              	
Clean Air Act for the knowing submission of false statements to EPA.

11/12/86.  Wiatt pled guilty to a six-count criminal  information charging him with
submitting fraudulent docuaents to EPA in violation of Sec. 113(c)(2) of the Clean
Air Act  [42 U S.C. §7413(c)(2)].

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                                                                                                                04/22/87 - 3
                                         ENVIRONMENTAL INVESTIGATION INITIATED  WITH
                                            CLEAN AIR ACT (CAA)  AUTHORITY  (cont.)
Defendant s)/0ocket No /Court
Custom Engineering, Inc
Billy Closson
Roger Scoggins
John Sidwell
36-00513
(C D  Cal )
Mano A  Segale
M  A  Segale. Inc
Wilham Bartholomew
85-267
(W 0  Wash )
Euro-Auto Lta .  Inc
James S  Strecner. Jr
Barbara A  Strecker
86-95TB
(w 0  Wash)
                                                                         Facts  and  Status
                                                    EPA Region  VI  (cont.)
Edward F  Wiatt                         12/01/86   Alston sentenced  to  $24,000  fine,  including restitution payments of
  (cont.)                               approximately $3,800  and 6 months probation.  Williams sentenced to 3 years probation
                                        and 80 hours of community  service.

                                        12/17/86   Wiatt sentenced to $1,500  fine  and 150 hours of community service

                                                        EPA Region IX
                                        Facts    Submission of testing results and  supporting documentation to EPA by auto-
                                        moDile emissions testing ("gray market") laboratory in Garden Grove stating that
                                        certain nonconforming vehicles  were tested under required Federal testing procedures
                                        and met applicable emission  standards.  Closson is president, Scoggins is manager ana
                                        Sidwell works as technical director
                                        06/10/86.   36-count indictment  returned charging  each  defendant as  follows.

                                             Company and Closson  -  18 counts mail  fraud [18  U  S.C.  §1341] and  15 counts making
                                             false statements  [18 U S C.  §1001] for  alleged  submission of false testing
                                             results.

                                             Scoggins  •  13 counts mail  fraud and  11  counts  false  statements.

                                             Sidwell -  Four counts  mail  fraud  and four counts  false statements, plus  three
                                             counts perjury [18 U.S C   §1623]  for making  false declarations to the  grand
                                             jury

                                        12/10/86-   Custom Engineering and Closson each pled  guilty to  five  counts of  making
                                        false statements to the Federal  government and four  counts of  mail  fraud    Scoggins
                                        pled guilty to  two counts of mail  fraud and  Sidwell  pled  guilty to  two false  state-
                                        ment counts

                                        03/31/87   Scoggins and Sidwell  each olaced  on 5  years probation

                                                        EPA Region  X
                                        Facts.   Ashpalt manufacturer ooerated  new source  and gases discharged  in  excess of
                                        performance standards  with  respect to  opacity   Segale is Company president ana
                                        Bartholomew is  division manager

                                        11/14/84.   Information filed charging  Comoany.  Segale and Bartholomew  with  four
                                        counts violation of Clean Air Act Sec   113(c)(l)  [42 U S  C  §7413(c)(D]

                                        03/11/85.   Court dismissed  all  charges against  defendants.

                                        04/16/85   Information refiled  charging same defendants with same  four counts of
                                        violating opacity standards

                                        09/10/85   Office of United States Attorney  agreed to defense  motion to dismiss all
                                        charges on ground that state inspector making opacity recordings  had not  been certi-
                                        fied by EPA within 6 months preceding  violation

                                        Facts   Strecker, an automobile dealer in Auburn, his wife, Barbara and Euro-Auto
                                        Ltd., Inc  , the corporate dealership,  are involved in auto importation

                                        12/17/86   74-count indictment  returned charging defendants with  violations arising
                                        from fraudulent scheme to avoid required auto-emission standards  for "gray market"
                                        vehicles imported under EPA "5-year exemption "   J  Strecner and  Company also cnargea
                                        with violations relating  to falsification of OOT-required odometer  mileage state-
                                        ments.   Specific charges  are as follows

                                             J.  Strecker and Company -  14 felony counts  for the roll-back of odometer mileage
                                             settings [15 U.S.C.  §1990(c)], two counts  conspiracy (one for odometer fraud)
                                             [18 U S C  §371], 40 counts making false statements to three Federal agencies
                                             [18 U.S.C.  §1001],  and 18 counts  smuggling [18 U.S.C  §545].

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                                                                                                                04/22/87 - 4.
                                         ENVIRONMENTAL INVESTIGATION INITIATED WITH
                                            CLEAN AIR ACT (CAA)  AUTHORITY  (cont.)
Oefendant(s)/Docket No /Court
Euro-Auto Ltd
  (cont )
Albert Mardikian
Garo Mardikian
85-00509
(C.O  Cal )
Sembat Agoo
85-00782
(C 0  Cal )
                                                                         Facts  and  Status
                                                   EPA Region X (cont.)
                jnc                          B. Strecker - One count conspiracy, 32 counts making false statements to Federal
                                            agencies and 18 counts smuggling.

                                       03/12/87-  Superseding indictment filed charging all counts described above and an
                                       additional 18 counts of smuggling against each defendant

                                          EPA-NEIC Nationally Managed  Investigation
                                       Facts.  Automobile import and  emission testing facility in Orange County used mail
                                       fraud  scheme to defraud EPA and Customs Service regarding importation of motor
                                       vehicles  not conforming to Clean Air Act emissions  standards and submitta! or false
                                       test data to EPA from mid-1981 until 1984   Albert  Mardikian was chief operation
                                       officer and Garo is Albert's nephew and plant manager   Agob was an employee of
                                       Albert Mardikian Engineering,  Inc.
                                        05/22/85    35-count  felony  indictment charging Albert Mardikian with  17 counts mail
                                        fraud  [18  U S  C.  §1341]  and 18 counts false statements [18 U.S C  §1001].  Garo
                                        Mardikian  charged with 10 counts of mail  fraud.

                                        08/07/85    Trial  began

                                        08/08/85    During presentation of  government's case. Albert MardikiJn entered guilty
                                        plea to nine counts  false statements and  one  count  mail  fraud   Garo  Mardikian
                                        entered guilty plea  on same date to three counts  mail  fraud.

                                        08/12/85    One-count information filed  charging Agob with one  count false  statements
                                        [18 U.S C   §1001]

                                        08/13/85    Agob waived  indictment  and pled guilty

                                        11/04/85.   Agob sentenced  to 5 years  imprisonment (all  but  20  days  suspended and
                                        served on  weekends), 5 years probation  plus 2,500 hours  community service

                                        11/25/85    Albert Mardikian sentenced to  5 years  imprisonment  (all  but 6 months sus-
                                        pended).  5 years probation  plus 2080  hours community  service consisting of at least
                                        8 hours per week over 5  year period  teaching under-privileged  individuals  now to
                                        improve job seeking  skills. Albert also required  to place  no  fewer  than 20 indi-
                                        viduals each year into  jobs plus  restitution to  injured  parties.   Garo Mardikian
                                        sentenced to 5 years imprisonment  (all  but 30 days suspended  and  served on weekends).
                                        5 years probation plus  community  service  over 5-year period                  	_

George~Timotny~Mercier                  Facts.  Amount of lead used by  Company  understated in 1984 quarterly reports ^"'^c
Timothy Scott McLeod                    by "lead phasedown"  regulations  promulgated under Clean Air Act.  Sec. 211.  Mercier
  (Gulf States Oil and Refining         is former head of Company's fuel-blending operation and McLeod was  chemist

86-OOin                                04/11/86-   Five-count indictment  filed  charging Mercier and McLeod each with one

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                               SECTION  III

                          Clean Water Act (CWA)


Clean Water Act (CWA)  	  33 USC §§  1251-1373
                                                        PL 92-500
                                                        PL 95-217

Marine Protection, Research
  and Sanctuaries Act  (MPRSA)  	  33 USC §§  1401-1445
                                                        PL 92-532

Refuse Act of 1899 (RA)  	  33 USC §§  407,  411
                                                        PL 55-425

Rivers and Harbors Appropriations
  Act of 1899 (RHAA)  	  33 USC §§  403,  409
                                                        PL 55-425

Safe Drinking Water Act  (SDWA) 	  42 USC § §  300f-300j
                                                        PL 95-190

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                                                                                                                04/22/87  -  1
                                         ENVIRONMENTAL INVESTIGATION  INITIATED WITH
                                               CLEAN WATER  ACT (CWA)  AUTHORITY
Oefendant(s)/Docket No /Court
                                                                         Facts and  Status
K.  W. Thompson Tool  Company. Inc.
  (aka Thompson Center Arms)
Robert Gustafson
Joseph Behre
Emmett Ronayne
85-08
(D N H )
                                                       EPA Region I

                                        Facts   Dumping of hazardous waste, including cyanide, barium, potassium nitrate antf
                                        sodium  hydroxide, into ditch emptying into Cocheco River and into ground for percola-
                                        tion    Casting wax containing PCBs improperly stored and no records maintained.   Com-
                                        pany  is metal casting and firearms manufacturer in Rochester   Gustafson is president
                                        and Ronayne  and Behre were vice presidents.

                                        03/18/85.  50-count indictnent filed charging:

                                             Company and Ronayne - 41 counts discharge of pollutants without permit in viola-
                                             tion  of Clean Water Act. Sees. 301 and 309(c)(l) [33 U.S C. §§1311 and
                                             1319(c)(l)l, three counts violating storage, marking and recordkeeping standards
                                             relating to PCBs under TSCA [15 U.S.C  §2614], one count treatment, storage ana
                                             disposal of hazardous waste without permit under RCRA, Sec. 3008(d)(2) [42
                                             U  S C  §6928(d)(2)]. one count failure to notify of release of hazardous sub-
                                             stance  in violation of CERCLA, Sec. 103(b) [42 U.S.C. §9603(b)]. one count
                                             failure to notify of existence of hazardous waste disposal facility in violation
                                             of CERCLA. Sec.  103(c) [42 U.S.C. §9603(c)]. one count false  statements  in
                                             response to industrial waste questionnaire [18 U.S.C. §1001]  and two counts con-
                                             spiracy to violate Clean Water Act (misdemeanor) and RCRA  (felony).

                                             Behre • Charged  on all same counts except false  statements.

                                             Gustafson - 41 counts violation of Clean Water Act, Sees   301 and  309(c)(l). and
                                             three counts violation of TSCA standards

                                        06/24/85.  Jury viewing of site conducted  by  Court.

                                        06/25/85.  Trial began

                                        07/01/85.  Company  entered guilty plea  to  15  counts  in  violation of Clean Water Act.
                                        Sees   301  and 309(c)(l), one count under CERCLA.  103(b)  and one count  under CERCLA.
                                        103(c)

                                        07/02/85-  Company  sentenced to $4.000  fine  on each  Clear Water Act count  plus  $7,500
                                        on each CERCLA count  for total of $75,000.   Charges  against  individuals dismissed

USH Corporation                         Facts.   J. C. Rhodes  Division of corporation failed  to  submit reports  on wastes  dis-
86-365F                                 charged to local POTW from electroplating  operations  of its New Bedford plant for  tne
(0.  Mass.)                              production of shoe  components

                                        11/10/86  41-count indictment  filed  charging Company witn  32 counts  failure  to con-
                                        ply with pretreatment standards  in  violation of  Clean Water Act.  Sees   30/  and  3Q9(c)
                                        [33 U.S.C. §§1317  and 1319(c)].  five  counts  discharge of wastewater into POTT* in vio-
                                        lation of Clean  Water Act.  Sees.  307  and  309(c),  and four counts  failure to submit
                                        required reports  in violation  of  Clean Water Act. Sees   307.  308 and  309(1) [42
                                        U S.C.  §§1317,  1318 and 1319(c)].

                                        12/30/85:   Company pled guilty  to  all  41  counts  and sentenced to fine  of $1,025.000
                                        with $225,000 suspended if  Company completes construction of wastewater treatment
                                        system by 10/03/87

                                                        EPA Region  II

                                        Facts   Frenkel,  owner of  ECTS,  hired as  consultant to  study disposal  alternatives
                                        for sewage treatment systems in Salem County   Project funded under Clean Water Ac:,
                                        Sec  201
Nathan Frenkel
Environmental Consulting and
   Testing Service,  Inc.
83-00047
(D.N J )
                                        03/02/83-  Four-count indictment returned charging each defendant with three counts
                                        false statements [18 U.S.C. §1001] for misrepresentations of number of hours wornea
                                        and one count conversion of government property [18 U.S C. §641] for vacuum cleaner
                                        taken from United States Naval Air Development Center

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                                                                                                                 04/22/87 - 2
                                         ENVIRONMENTAL INVESTIGATION INITIATED WITH
                                           CLEAN WATER ACT (CWA) AUTHORITY (cont.)
Defendants I/Docket No. /Court
                                                  Facts  and  Status
Nathan Frenkel
  (cont.)
                             EPA  Region  II  (cont.)
                 05/23/83.   Frenkel  pled guilty  to one  count conversion of government property and
                 Company pled guilty to  one count false statements

                 07/08/83:   Frenkel  sentenced  to $7,500 fine and Company to $5,000.
Coastal Steel Corporation
  (Republic Wire Corporation)
82-01478
(0 N J )
Robert Thomas Barnes
33-00214
(ED  va )
Environmental Systems Services
83-00246
(ED  Va )
                 Facts    Refuse  matter,  including  sanitary waste and waste rinsewater containing sul-
                 furic  acid,  discharged  into Woodbridge Creek.

                 11/17/82.   Information  filed charging 10 counts discharge of refuse in violation of
                 Sec   13 of  Rivers  and Harbors Appropriation Act of 1899 (Refuse Act) [33 U S C
                 §§407  and 411].

                 11/18/82-   Company pled guilty  to all 10 counts

                 01/13/83.   Company sentenced to $20,000 fine  ($15,000 suspended), community service
                 eaual  to $15,000 amount of suspended fine, and 3 years probation.   If. community
                 service not performed,  monetary equivalent of amount of service to  be paid as addi-
                 tional  fine

                                EPA Region  III
                 Facts    In  performing contract  work for NPOES permittees, Discharge .Monitoring
                 Reports (OMRs)  falsified as to  environmental  impacts of pollutants   Barnes was vice
                 president,  managing partner and minority stockholder.
                                        10/06/83   Barnes pled guilty
                                        false statements in violation
                                        §1319(c)(2)]
                                               to  information  filed  on  same  date  charging  two counts
                                               of  Clean Water  Act, Sec.  309(c)(2)  [33  U.S.C.
                 10/28/83    Barnes  sentenced  to $500  fine,  6 months  probation on  each  count, with
                 sentences  to  run concurrently, and 100 hours  community  service

                 11/14/83    Company pled  guilty to information filed same date charging  two counts
                 violation  of  Clean Water Act, Sec  309(c)(2)  [33  U  S C. §1319(c)(2)]  and  sentenced  to
                 $5,000 fine
William Garry Byles
85-00075
James C  Kostelm
85-00076
Daniel laVietes
85-00077
Georgia Bonded Fibeps.
85-00078
(W 0  Va )
Inc
Facts-   Joint investigation oy EPA.  Defense Criminal  Investigation Service and
Virginia Water Control  Board   Repeated instances of bypassing wastewater treatment
plant and discharging into Maury River, reporting fictitious laboratory results in
Discharge Monitoring Reports (OMRs)  and filing false statements pertaining to DOD
contract specifications concerning military baseball-type cap visors made using Com-
pany's  Bondex fiber ooard.   Kostelm was president,  LaVietes was former vice presi-
dent for research and Development and Byles was chief chemist.

10/17/85:  Defendants pled guilty to following charges in four separate informations
filed on this date

     Byles - Pled guilty to one count information charging false statements in OMRs
     in violation of Clean Water Act. 5ec  309(c)(2) [42 U S C  §1319(c)(2)] and
     sentences on same  date to S500  fine.

     Kostelm - Pled guilty to tnree-count information charging two counts discnarge
     of wastewater in violation of NPDES permit under Clean Water Act.  Sees  301 and
     309(c)(l) [33 U S  C.  §§1311 and 1319(c)(l)], and one count conversion of Govern-
     ment property under 000 contract [18 U.S.C.  §641].   Kostelm sentenced on same
     date to fines of $10,000, $10,000 and $500 on each count for total of $20.500
     (all but $5,000 suspended)

     Company - Waived indictment and entered guilty plea to three-count information
     charging one count discharge of pollutants into river in violation of NPOES
     permit under Clean Water Act, Sec. 309(c)(l), one count false statements in QHRs
     in violation of Clean Water Act, Sec. 309(c)(2) and one count false statements
     in certification under DOD contract [18 U.S.C.  §1001].  Company sentenced on

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                                                                                                                04/22/87 - 3
                                         ENVIRONMENTAL INVESTIGATION INITIATED WITH
                                           CLEAN WATER ACT  (CWA)  AUTHORITY  (cont.)
Oefendant(s)/Docket No./Court
William Garry Byles
  (cont.)
Columbia Marine Services,
William Kinzeler, Jr
John L  Kinzeler
82-36
(E 0  Ky )
                                                                        Facts and Status
                                                   EPA  Region  III  (cont.)
                                             same date  to  fines of $25.000, $10,000 and $10,000 on each count for total of
                                             $45  000  $15,000  restitution to Government as settlement of claim under False
                                             Claims Act, and directed  to reimburse Government for costs of investigation
                                             ($11,050 to EPA and $1,600 to 000).

                                             LaVietes - Charged with one count making false statements in DMRs under Clean
                                             Water Act. Sec  309(c)(2) and one count conversion of Government property
                                             [18  U.S C  §641]

                                        11/08/85    LaVietes pled guilty to all counts charged and sentenced to SI,500 fine
                                        (all  but  $500 suspended),  plus unsupervised probation for 2 years.

                                                       EPA Region IV
                          Inc           Facts  On four occasions, oil discharged near Ludlow into Ohio River from vessel
                                        owned and operated by  Company

                                        10/13/82    Four-count  indictment filed charging:

                                             Company -  Four counts failure to report discharge  of oil  in  violation of  Clean
                                             water Act, Sec  311(b)(5) [33 U.S.C  §1321(b)(5)].

                                             William Kinzeler  and  John Kinzeler - One count  failure  to  report oil discharge
                                             in violation  of Sec.  311(b)(5)

                                        10/25/82.  Company entered plea of guilty to two  counts.

                                        10/26/82    Company sentenced to $10,000 fine with credit  given  for $3,000 previously
                                        paid to Coast Guard.   Charges  against both  Kinzelers  dismissed.

James Holland                           Facts.   Owner of Middle  Keys Construction Company dredged and  filled  12  sites  in
83-891                                  lower and middle  Florida  Keys  between May 1980  and August 1983  and.  for  one  site.
(S D  Fla )                             fraudently represented to  landowners that all permits would  be  obtained.

                                        11/02/83.  22-count  indictment returned charging  11 counts  violation  of  Sec   10 of
                                        Rivers and Harbors Appropriation Act of 1899  [33  U S C.  §403],  eight  counts  violation
                                        of Clean Water  Act.  Sees.  301  and  309(c)(l) [33 U.S.C.  §§1311  and 1319(c)(l)]. ana
                                        three counts  mail  fraud  [18  U  S C  §1341].

                                        02/21/84-  Guilty  plea entered to  eight counts  under Clean  Water  Act  and three counts
                                        under Rivers  and  Harbors  Appropriation  Act

                                        06/07/85   Defendant sentenced to  5  years  probation and 400 hours community  serv.ce.
                                        Also required to  perform restoration at  four sites.
Louisville and Nashville Railroad
82-00146
(W.O  Ky )
Ocean  Reef Club,
Russell A  Post
Claude H  Gehman
Mark Mai lea
85-909
(S.D   Fla )
                  Inc
Facts-   Diesel fuel and other pollutants discharged through municipal  sewers  in
Louisville into POTW (creating hazard of fire and explosion) and Ohio  River

11/15/82.   Two-count information filed charging one count discharge of pollutants
without permit in violation of Clean Water Act. Sees.  301(a), 309(c)(l) and 4o2
[33 U S C  §§1311(a), 1319(c)(l) and 1342] and one count discharge of  pollutants  into.
POTW in violation of pretreatment standards, in violation of Clean Water Act,  Sees.
301(a). 307(d) and 309(c)(l) [33 U.S.C  §§1311(a), 1317(d) and 1319(c)(D]

11/16/82   Company pled guilty to both counts

11/16/82.   Company sentenced to $19,000 fine on each count for total of $38.000.

Facts   Discharge of raw sewage and sewage effluent from December 15,  1982 to Novem-
ber 10, 1983  into the Atlantic Ocean by means of diverting valves or bypass lines
installed in club's permitted sewage collection and treatment plant; also, falsifi-
cation of Discharge Monitoring Reports to EPA.  Post is Company president and cmef
operating officer, Gehnan is Coapany vice president and MaUa is employee in
utilities department.

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                                                                                                                04/22/87 - 4
                                         ENVIRONMENTAL INVESTIGATION  INITIATED WITH
                                           CLEAN WATER ACT (CWA)  AUTHORITY  (cont.)
Defendant(s)/0ocket No /Court
                                                                         Facts  and  Status
Ocean Reef Club, Inc
  (cont.)
Raymond Borowski
83-151
(N 0  111 )
Venus Laooratories,
85-00238
(N 0 ,  111 )
Jay woods Oil, Inc
Edmund woods
87-20012
(E.D  Mich )
                    12/05/85.
                    follows
 EPA Region IV (cont.)
346-count indictment  filed charging Company,  two officers and employee as
                                             Company,  Gehman and  Malka  • One misdemeanor  count conspiracy to violate Clean
                                             Water Act [18 U.S  C.  §371], one felony  count conspiracy to file false statements
                                             with and  conceal material  facts from  EPA  [18 U  S C. §371], 12 felony counts
                                             making false statements  [18 U.S.C.  §1001], and  332 misdemeanor counts discharg-
                                             ing pollutants without NPOES  permit and violation of permit conditions in vio-
                                             lation of Clean Water Act, Sees   301  and  309(c)(l) [33 U S C  §§1311 and
                         Post  - One  count conspiracy to violate Clean Water Act and 332 counts discharg-
                         ing  in violation of Clean Water Act, Sees  301 and 309(c)(l)

                    07/31/86   Company pled guilty to 40 counts discharging pollutants in violation of
                    NPOES permit  conditions.  Gehman and Malka each pled guilty to one count of same
                    charge.  Charges dismissed against Post.

                    10/22/86   Company sentenced to a $600.000 fine and will not be allowed to set aside
                    any  amount of that fine for environmental or other purpose.  Gehman was fined $5,000
                    and  Malka  was fined  $2,000 and each was placed on probation for one year.

                                    EPA  Region V
                    Facts  Defendant operated several municipal sewage treatment plants  in Oupage
                    County, Illinois, where, during period between October 1977 to July 1978, defendant
                    understated pollutant amounts by half for three of the plants when filing Discharge
                    Monitoring Reports required under Clean Water Act.

                    02/23/83.   13-count  indictment returned charging submittal of false information
                    [18  U S.C  §1001]

                    04/22/83   Defendent pled guilty to two-count superseding  information filed on same
                    date charging submittal of false information under Clean Water Act. Sec   309(c)(2)
                    [33  U S.C  §1319(c)(2)]

                    06/01/83   Defendant sentenced to 3 years orobation and 200 hours community service

Inc                 Facts.  Liquid chemical wastes, including cleansers,  drain cleaners and other clean-
                    ing  agents discharged  into tributary of Oes  Plains River without  permit   Company
                    allowed contaminated runoff to drain into river  via ditch  and was believed  to nave
                    hidden pipe connecting  plant drams to  city's  storm sewers  EPA  personnel  observed
                    highly contaminated  water entering river

                    04/17/85:   22-count  indictment filed charging Company with negligent  discharge of
                    liquid chemical  wastes  into river without permit in violation of  Clean Water Act.
                    Sees  301 and 309(c)(l)  [33 U S C  §1311 and 1319(c)(l)].

                    08/01/85    Company entered guilty plea  to  four  counts violation  of Clean  Water Act.

                    09/17/85-   Company sentenced  to $2,500  fine  on  each count  for $10,000 total

                    Facts  Jay Woods Oil,  Inc  ,  operated  a number  of  underground  injection wells  in  con-
                    junction  with its  oil  recovery operation    EPA  discovered  plugs  installed on  four
                    wells during  a mechanical  integrity  test.

                    02/13/87.   A  Federal grand  jury  indicted Jay Woods Oil,  Inc  and Edmund Woods  on  four
                    felony counts of concealing a material  fact  from EPA  by  trick,  scheme or  device  in
                    violation of  18 U.S.C   §1001    In  addition,  Woods  was charged with  having committed
                    perjury before a grand jury,  in  violation  of 18 U.S C  §1623, a  felony.   The  Comoany
                    and Woods were charged with deceiving  EPA  by placing  plugs into  four  underground
                    injection wells so  it  would appear  that they met the  mechanical  integrity test
                    requested by  EPA Region V under  40  CFR Part 144 promulgated  pursuant  to  the Safe
                    Drinking  Water Act [42 U S.C  §§300(f)  and  300(g)]

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                                                                                                                04/22/87 - 5
                                         ENVIRONMENTAL INVESTIGATION INITIATED WITH
                                           CLEAN WATER ACT (CWA)  AUTHORITY  (cont.)
Defendants )/Oocket No /Court
                                 Facts  and  Status
Harm, Inc
84-00026
William E  Pieber
84-00027
(E 0  Mo )
Eric Donald Roth Sr
85-00119
(E 0  Mo )
Dale L  Knoedler
Jim 0  Newman
Roger Swenson
  (Dugdale of Nebraska. Inc.)
84-00059
(0  Neb )
               EPA Region VII
Facts.   False statements  contained  in  Discharge  Monitoring Reports and BOO limits
in NPOES permits exceeded by wastewater  treatment  plant  in Fenton.  Pieber is man-
ager of Company's wastewater treatment facility

02/13/84   Five-count information filed  against  Company  charging  four counts viola-
tion of Clean Water Act,  Sees   301(a)  and  309(c)(l)  [33  U S C  §§1311(a)] and
1319(c)(l)] and one count false statements  [18 U S.C  §1001]   Two-count information
filed on same date charging Pieber  with  two counts  in  violation of Clean Water Act,
Sees  301(a) and 309(c)(l)

02/15/84   Pieber pled guilty  to all charges

02/17/84   Company pled guilty to all  charges.

03/09/84   Peiber sentenced to 30 months probation,  150  hours  community  service and
$2,500 fine.
                                        03/23/84
           Company sentenced to  5  years  probation.  $10,000  fine  on  false  statement
count and S10.000 fine on one Clean  Water  Act  count;   $15,000  fines  imposed  on eacn
of three remaining Clean Water Act counts,  execution  suspended pending submission and
court approval  of community work plan  within 90  days.   In  lieu of community  service.
545,000 in fines could be paid to  designated charity.

08/16/85   Pieber's term of probation  reduced  to 24 months.

Facts   Five cities paid chemical  laboratory  in  Festus to  perform tests required oy
Clean Water Act permits   Laboratory owner submitted  false  Discharge Monitoring
Reports to Missouri Deoartment of  Natural  Resources.   Statements of  business
associates indicated knowing violations

05/23/85   10-count indictment filed charging  Roth (d/b/a  Analyst Consulting Labora-
tories, Inc ) with three counts  false  statements [18  U.S.C   §1001],  two counts
mail fraud [18 U S C  §1341] and five  misdemeanor counts of false statements under
Clean Water Act. Sec  309(c)(2)  [33  U  S  C   §1319(c)(2)].

08/01/85:   Roth pled guilty to one felony  count  of false statements  and two  misae-
meanor counts of false statements

09/06/85:   Roth sentenced to 4 months  imprisonment on each Clean Water Act count
(terms to run concurrently)   Sentencing on felony count suspended  pending complet'^n
of 5 years probation and 200 hours community service

Facts   Routine EPA inspection discovered facility lacked  technical  capability  to
analyze samples for fecal coliform (FC)  parameters   Discharge Monitoring Reports
stated "0" FC discharge, lab denied  testing   Knoedler is  sewage treatment techni-
cian, Newman is controller, ana  Swenson  is plant manager

11/19/84.   Five-count information  filed  charging Knoedler  and Newman with four counts
submitting false statements under  Clean  Water Act. Sec  309(c)(2)  [33 U S.C
§1319(c)(2)]   Swenson charged with  one  count violation of permit conditions under
Clean Water Act, Sees. 301 and 309(c)(l) [33 U S.C. §§1311 and 1319(c)(D]

12/04/84   Knoedler pled guilty  to two counts violation of Clean Water Act,  Sec
309(c)(2) and sentenced to 1 year  prooation and S300  fine  on each  count plus court
costs

03/26/85   Five-count superseding  information filed against Newman  and Swenson cnarq-
ing Newman with four counts violating NPOES permit conditions and  Swenson with one
count of sane violation, all under Clean Water Act, Sees  301 and  309(c)(l).

06/03/85:   On scheduled trial date,  all  charges against Swenson  and Newman dismissed
on motion by Office of United States Attorney

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                                                                                                                04/22/87 - 6
                                         ENVIRONMENTAL INVESTIGATION  INITIATED WITH
                                           CLEAN WATER ACT  (CWA)  AUTHORITY  (cont.)
Defendants)/0ocket No./Court
                                                   Facts and Status
Arnold N.  Graham
  (TWA)
86-00137
(W.O. Mo )
Rocky Mountain Materials and
  Excavating, Inc
85-350
(0.  Colo.)
Ralph Burgholzer
lavell Mclntire
86-00261
(0. Ariz )
William C  Cairns
David G  Chevalier
Charles 0  Hudson
Donald 0  Johnson
The Wyckoff Comoany,
84-00167
(W 0  Wash )
Inc
                             EPA Region VII (cont.)
                   Facts:  Employee of TWA in charge of wastewater treatment plant at overhaul  base in
                   Kansas City  received illegal kickback payments from chemical supplier for plant and
                   falsified Discharge Monitoring Reports (DMRs) submitted to Missouri Department of
                   Natural Resources.
                                                                                                                       one
                                          Iuilty to two-count information filed same date charging
                                               371] and one count false statements to EPA in violation
07/30/86:   Graham pled
count conspiracy [IB U.S C  ,....  	
of Clean Water Act,  Sec.  309(c)(2) [33 U.S.C.  §1319(c)(2)].
09/18/86   Defendant sentenced to 3 years  and  6 months  imprisonment  (all but 6 months
suspended), $10,000 fine on conspiracy charge  with  additional  6 months of  imprison-
ment, $10,000 fine on false reports charge,  sentences  to run consecutively, plus 5
years probation, 200 hours community service and $21,075 restitution to TWA.

               EPA Region VIII
Facts   Soil contaminated with pentachlorophenol  discharged onto  banks and into  flooc
plain of Fountain Creek.

12/23/85   Company entered guilty plea to  information  filed on sane  date  charging  one
count discharge of pollutants without an NPOES permit  in violation of Clean Water
Act. Sees. 301 and 309(c)(l) [33 U S.C  §§1311 and  1319(c)(l)]

02/13/86   Company sentenced to $10,000 fine plus $100 assessment to Crime Victims
Fund.

05/05/86   Company listed on EPA's List of Violating Facilities  as a result of Clean
Water Act violation   Pursuant to 40 CFR Part  15. facility may not be used in any
new, renewed or extended Federal contract, subcontract, grant, loan, sudgrant or
subloan

                EPA Region IX
Facts:  Raw sewage discharged into Colorado River through POTW owned by  Coloraao
River Sewage System Joint Venture (JV)  Mclntire is JV chairman of the  board  ana
Burgholzer is plant operator

09/17/86:  Four-count indictment charged each  defendant with  discharging pollutants
into navigable waters without a permit in  violation of Sees  301(a) and  309(c)(l)  of
the Clean Water Act [33 U S C  §§1311(a) and 1319(c)(l)]

03/17/87:  Superseding indictment filed cnarqing Burgholzer and Mclntire with  15
counts unpermitted discharges in violation of  Clean Water Act and Burgnolzer with
one count making false statement in violation  of 18 U S C  §1001.

                EPA Region X
Facts-  Company engaged in pressure-treating wood products with preservatives  con-
taining creosote, pentachlorophenol ana arsenic   Polluted water pumped from  unl;nea
holding pit via fire nose into nearby storm drains  leading directly into Ouwamish
River   Contaminated water siphoned from  lagoon on Company property into Elliott Bay
Cairns is Company's president. Chevalier  is former general supenntendant, tiuason  is
technical director and Johnson is chief engineer

06/21/84   12-count  indictment filed charging Cairns. Chevalier, Hudson, ana Johnson
with seven counts violation of Clean Water Act,  Sees.  301 and 309(c)(l) [33 U S C
§§1311 and 1319(c)(D], one count storage and disposal of hazardous wastes without
permit in violation of RCRA,  Sec. 3008 (d)(2)  [42 U.S C  §6928(d)(2)], two counts
conspiracy [18  U S.C  §371] and two counts  false statements [18 U.S.C. §1001]    Com-
pany charged with seven counts violation  of Clean Water Act,  Sees.  301 and 309(cKD
one count violation of RCRA,  Sec. 3008(d)(2),  one count conspiracy  [18 U S.C
§371] and two counts false statements [18 U.S C. §1001].
                                        01/24/85:  All defense pretrial motions denied

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                                                                                                                04/22/87 - 7
                                         ENVIRONMENTAL  INVESTIGATION  INITIATED WITH
                                           CLEAN WATER  ACT (CWA)  AUTHORITY  (cont.)
Defendants I/Docket No /Court
                                                                         Facts and Status
William C. Cairns, etc.
  (cont.)
                       EPA Region X (cont )
           03/11/85:  On scheduled trial date, all same defendants pled guilty to four-count
           superseding information as follows.

                Comoany - One count storage of hazardous waste without permit in violation of
                RCRA, Sec. 3008(d)(2)(A), one count discharge of pollutants without permit in
                violation of Clean Water Act, Sees  301 and 309(c)(D and one count conspiracy
                to  violate Clean Water Act

                Cairns - One count storage of hazardous waste without permit in violation of
                RCRA. Sec. 3008(d)(2)(A).

                Chevalier, Hudson and Johnson - One misdemeanor count each of conspiracy to
                violate Clean Water Act [18 U.S.C. §371]

           04/19/85-  Defendants sentenced as follows:

                Company - As per plea agreement,  fined $1,000,000 (all but $150,000 suspended).
                5 years probation on condition it obey all laws, expeditiously clean up facility
                and pay $850,000 into trust account administered by Region X for study and
                cleanup of site.

                Cairns - 1 year imprisonment  (all but 60 days suspended). 2 years  probation,
                525,000 fine

                Chevalier - 2 years probation plus 200 hours community service; $10,000 fine.

                Hudson • 2 years probation plus  150 hours community service. $5.000 fine

                Johnson - 2 years probation plus  100  hours community  service, $2,500 fine.

                All individual  fines to be oaid  from  personal  funds
Richard C. Woeck
Peter f  Woeck II
Lloyd Anderson
Frank Brady
Marine Power and Equipment,
86-128
(W 0. Wash )
            Facts.   Discharge  of  sand blast waste  laden with  toxic  heavy metals  including  lead.
            arsenic and copper into  Lake Union  and Ouwamish River    Company  involved  in  ship
            building operations.   R  Woeck  is president.  P  Woeck  is vice president and  superin-
            tendent of new construction, Anderson  is  vice president and Brady  is  ship repair
Inc         superintendent.

            05/08/86:   115-count  indictment returned  charging

                 R.  Woeck - One count conspiracy  [18  U.S  C  §371],  113 counts  discharging  poilu-
                 tants without permit in violation of Clean water  Act, Sees.  301(a) and  309(c)U)
                 [33 U.S C  §§13il(a) and  1319(c)(l)] and one count obstructing  navigable  water-
                 way in violation of Section  10 of Rivers and Harbors Appropriations  Act of  12S5
                 [33 U S C  §§403 and 406]

                 P  Woeck and  Anderson  - One  count conspiracy and  113 counts discharging pollu-
                 tants without permit

                 Brady - One count conspiracy and 81  counts discharging  pollutants without
                 permit

                 Company - 113 counts discharging pollutants  without permit  and  one count
                 obstructing navigable  waterway

            12/01/86:   Corporation,  Peter  and Richard Woeck and Anderson each pled guilty  to  two-
            count information filed that date charging negligent discharge  of pollutants in  v.o-
            lation of Clean Water Act.  Sees.  301(a)  and 309(c)(l)  [33 U  5 C.  §§1311(a) and
            1319(c)(l}].  Charges against  Brady dismissed.

            04/10/87:   Marine Power was sentenced to pay a  $200,000 fine and placed on probation
            for 3 years.  Richard Woeck was sentenced to pay  a $4.000 fine,  serve 5 days of  a
            1-year tern of imprisonment and provide  300 hours of community  service.   Peter woecu
            was sentenced to pay a $3,000  fine, serve 5 days  of a 1-year tens of imprisonment ant
            provide 300 hours of comaunity service and placed on probation  for 3 years.   Andersoi
            was sentenced to pay a $1.000  fine and placed on probation  for  3 years.

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                                                                                                                 04/22/87  - 8
                                         ENVIRONMENTAL INVESTIGATION INITIATED WITH
                                           CLEAN WATER ACT (CWA) AUTHORITY (cont.)
Defendants)/0ocket No./Court
                                                    Facts and Status
Paul 0  Schwitters
Sea Gleaner Marine,
86-00129
(W.O. Wash )
Inc
Bruce Norman Barker
Washington Boat Center,
86-00127
(W D  Wash )
Sam Jenkins, Jr.
Sea Port Bark Supply,
86-31
(W D  Wash  )
  Inc
Willard L  Kaser
36-00040
Nabisco Brands. Inc
86-00041
William Parks
86-00042
(W.D  Wash )
                                                    EPA Reoion X (cont.)
                    Facts
                        Spent  abrasive  blasting grit and paint particles discharged into Lake Union.
                Schwitters  is  chief  operating officer.

                05/08/86-   Information  filed charging Schwitters and Company each with four counts
                discharging pollutants  without permit in violation of Clean Water Act, Sees.  301(a)
                and  309(c)(l)  [33  U.S.C.  §§1311(a) and 1319(c)(l)].

                08/14/86:   Jury  returned  guilty verdicts on three counts against each
                defendant.

                10/06/86.   Corporation  sentenced to a $60,000 fine (all but $30,000 suspended) and
                5  years  probation  plus  $300 penalty assessment to Crime Victims Fund.  Schwitters
                sentenced to $15,000 fine (all but $5.000 suspended) and placed on probation for
                1  year plus $75  penalty assessment to Crime Victims Fund.

                Facts:   Dredged  spoils  discharged into Lake Washington Ship Canal, and Army Corps of
Inc.             Engineers investigator  falsely informed that large dredging pump was  used not to
                dredge but  for removal  of silt cloud   Barker is chief operation officer.

                05/08/86.   57-count  indictment filed charging Barker and Company each with one count
                false  statements [18 U.S.C. §1001] and 56 counts willfully and negligently discharg-
                ing  pollutants without  permit in violation of Clean Water Act, Sees.  301(a),
                309(c)(l) and  404  [33 U S C  §§1311(a), 1319(c)(l) and 1344].

                08/01/86:   Defendant's  motion to dismiss false statement count granted based on
                "Exculpatory No" doctrine

                08/04/86.   Trial begins

                08/07/86-   After 4 days of trial, court ordered judgment of acquittal of all remain-
                ing  counts  for each  defendant
                Facts:   Liquid waste  from bark processing discharged  into Hylebas Waterway
                is  owner of  Company.
                                                                                                                     Jenkins
                    04/15/86:   Information  filed charging Company  and  Jenkins each with  three counts dis-
                    charging  pollutants  into navigable water without NPOES permit in violation of Clean
                    Water  Act.  Sees.  301(a) and 309(c)(l) [33 U  S  C  §§1311(a) and 1319(0(1)]

                    06/11/86.   Company and  Jenkins each entered  guilty pleas to one Clean Water Act
                    count.

                    08/29/86:   Company sentenced to  $2,500  fine  ($1,500 suspended) which includes $100
                    mandatory penalty assessment to  Crime Victims  Fund and one year probation   Jen
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                                                                                                                 04/22/87 - 9
                                         ENVIRONMENTAL INVESTIGATION INITIATED WITH
                                           CLEAN WATER ACT (CWA) AUTHORITY (cont.)
Defendants I/Docket No /Court	Facts and Status	

                                                    EPA Region X (cont.)
Willard L  Kaser                        06/27/86:   Company sentenced to $450,000 fine (execution of $150.000 suspended),  and
  (Cont )'                              directed to establish Environmental Trust Fund in amount of $150,000 for enhancement
                                        of fish and game fish resources and hatcheries in Stuck, White and Puyallup Rivers
                                        plus $200 penalty assessment for Crime Victims Fund and 3 years probation

                                        07/18/86-   Parks sentenced to $2,500 fine and 3 years probation plus 250 hours  com-
                                        munity service

                                        09/12/86   Kaser sentenced to $5,000 fine and 1-year and 1-day term of imprisonment
                                        of which he must serve at least 9 months and 18 days plus $75 assessment to Crime
                                        Victims Fund.

                                        12/86   Fleischman's Yeast, Inc. added to the "Consolidated List of Debarred, Sus-
                                        pended and Ineligible Contractors" for an indefinite period.

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                                SECTION IV

        Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
Federal Insecticide, Fungicide
  and Rodenticide Act (FIFRA) 	 7 USC § 136
                                                       PL 92-516
                                                       PL 95-396

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                                                                                                                 04/16/87  -  L
                                         ENVIRONMENTAL INVESTIGATION INITIATED WITH
                            FEDERAL INSECTICIDE. FUNGICIDE AND RODENTICIOE ACT (FIFRA)  AUTHORITY
Defendants)/Docket No. /Court
                                                                         Facts and Status
Bryce Anderson
Randy Zimmerman
83-00038
(D  Neb.)
John Martin Anderson
  (A  C  Supply, Inc )
84-00056
(0  Wyo )
Ross L  Talbott
Ross M  Talbott
  (Talbott Enterprises,
85-00012
(0  Colo )
W  B. Sprague Company,
Alfred H  Treleven
Laurence R  Treleven
84-36
(W 0. Wash )
                                                       EPA Region VII

                                        Facts-  Ortho Paraquat CL, a registered pesticide for restricted use, applied without
                                        EPA certification.  Anderson, once a certified applicator, had let certification
                                        lapse.

                                        06/13/83.  One count information filed charging each defendant with violation of
                                        FIFRA [7 U S C. §136j].

                                        07/26/83   Anderson pled guilty to one FIFRA count and sentenced to J100 fine (ne had
                                        been recertified by EPA prior to sentencing).  Charges against Zimmerman dismissed

                                                       EPA Region VIII
                                        Facts:  Restricted use pesticide (diclofop methyl) sold to (uncertified applicator
                                        for use on applicator's ranch, and required records concerning sales of xylene
                                        falsified   Also pesticides discharged into Big Horn River without NPDES permit.
                                                   Six-count indictment filed charging four counts violation of FIFRA [7
                                        U.S.C. §136j(a)], one count violation of Clean
                                        06/22/84
                                         ...           ,                               Water Act,  Sees.  301 and 309(c)(l)
                                        [33 U S C  §§1311  and 1319(c)(l)].  and one count false statements [18 U.S.C.  §1001].

                                        09/18/84   Defendant pled guilty to three FIFRA counts and one count violation of
                                        Clean Water Act

                                        11/20/84-  Defendant sentenced to 3 years probation plus compliance with all  environ-
                                        mental  laws for 18 months and $5,000 contribution to Bid Horn County Agricultural
                                        Extension Service  or, in the alternative, fine of $6,150.

                                        Facts   Azinphos methyl  SOW, a restricted use pesticide, applied inconsistent witn
                                        labeling to apple  orchard and trailer park in New Castle.   Failure to notify  tenants
                        Inc )           and prevent re-entry for 48 hours,  as required.   Defendants were corporate
                                        principals

                                        01/11/85   One-count information filed charging both defendants with violation of
                                        FIFRA.  Sees  12 and 14 [7 U S C  §§1361(b)(2) and 136j(a)]

                                        02/25/85:  Both defendants pled guilty to petty offense

                                        03/25/85:  Ross L.  Talbott sentenced to $100 fine and Ross M.  Talbott fined $50

                                                        EPA Region X

                       Inc              Facts.   Commercial pesticide applicators several times used strychnine in grain belt
                                        to kill buds threatening grain elevators' contents.  Records falsified, listing use
                                        of nonrestricted pesticide.  Alfred Treleven is Company's retired president and
                                        Laurence Treleven  is current president.

                                        06/06/84-  Two-count indictment filed charging Company with one count violation of
                                        FIFRA [7 U S.C. 136j(a)], Alfred Treleven and Laurence Treleven each with one count
                                        violation of FIFRA and one count violation of Migratory Bird Treaty Act.
                                        06/29/84:   Company pled guilty to information and sentenced to $20,500 fine
                                        levens pled guilty to information and fined $5,500 each
                                                                                                                      Tre-

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