&EPA
AgETULf
         Environmental  Crimes  Case  Bulletin
                    U.S. Environmental Protection Agency
            Office of Criminal Enforcement, Forensics and Training
                        Case  Bulletin July 2012

 This bulletin summarizes publicized investigative activity and adjudicated cases conducted
 by OCEFT Criminal Investigation Division special agents, forensic specialists, and legal sup-
 port staff.
Defendants in this edition:
• Steven Avery, Billy Avery, Sea Solutions, Inc. — Region 3
• Nupro Industries Corporation — Region 3
• Payongyut Vongvichuankul & Pakpoom Hanprap — Region 4
• Duane "Butch" O'Malley — Region 5
• Team Industrial Services, Inc. — Region 6
• Port Arthur Chemical and Environmental Services LLC & Matthew L. Bowman — Region 6
• Odysea Carriers, S.A. — Region 6
• Jason Prejean & One Low Price Cleaners — Region 6
• Asgard Associates, LLC — Region 9
• Bret A. Simpson — Region 10
• Tammy Young — Region 10
                                                              EPA Bulletin July 2012  1

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                           DEFENDANT SUMMARY:
           REGION
         DEFENDANTS
     CASE TYPE/STATUTES
Region 3
Steven Avery, Billy Avery, Sea
Solutions, Inc.
 CWA/Spilling oil, oily water and
 other pollutants into U.S. waters
Region 3
Nupro Industries Corporation
                                                               CW A/Criminally tampering with
                                                                     wastewater samples
Region 4
Payongyut Vongvichuankul &
Pakpoom Hanprap
 APPS/Discharged oily bilge waste
 into ocean and failed to maintain
         oil record book
Region 5
Duane "Butch" O'Mallev
CAA/Illegal asbestos removal, han-
         dling, disposal
Region 6
Team Industrial Services, Inc.
 CAA/Negligent release of hazard-
         ous pollutants
Region 6
Port Arthur Chemical and Envi-
ronmental Services, LLC & Mat-
thew L. Bowman
 Hazardous Materials Transporta-
tion Uniform Safety Act & RCRA/
Illegal transportation of hazardous
    waste and false statements
                                                                              EPA Bulletin July 2012  2

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                           DEFENDANT SUMMARY:
          REGION
         DEFENDANTS
     CASE TYPE/STATUTES
Region 6
Odysea Carriers, S.A.
  CWA/Illegal dumping of oily
      waste into the ocean
Region 6
Jason Prejean & One Low Price
Cleaners
 CW A/Negligent discharge of haz-
    ardous waste into POTW
Region 9
Asgard Associates, LLC
 RCRA/Unlawful hazardous waste
            storage
Region 10
Bret A. Simpson
CW A/Failure to report unlawful oil
spill and unlawfully discharging oil
Region 10
Tammy Young
  SOW A/Falsifying Test Results
                                                                            EPA Bulletin July 2012  3

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 Quick Links:
 •                                 p. 4 - 8
 •                                 p. 9 - 11
 •                                 p. 12
                                                (Back to Quick Links)
Ship Scrapping Company and Owners Sentenced for Environmental Crimes - On July 12, 2012, STE-
                                                        VEN  E.  AVERY,  of  Bohannon,  Va.,
                                                        BILLY J. AVERY, of Virginia Beach, Va.,
                                                        and the  corporation SEA SOLUTIONS,
                                                        INC., were sentenced in federal district court
                                                        for the Eastern District of Virginia for vari-
                                                        ous environmental  crimes  stemming from
                                                        their activities in the ship scrapping busi-
                                                        ness.  Steven Avery was sentenced to  one
                                                        year  in  prison  and a $25,000 fine, Billy
                                                        Avery was sentenced to five years probation,
                                                        nine  months home confinement,  and  a
                                                        $25,000  fine, and  Sea  Solutions, Inc. was
                                                        sentenced to one year probation and is barred
                                                        from working in the  ship  scrapping busi-
                                                        ness. The three defendants were also collec-
 Boom is placed around the M/V Snowbird after an oil leak is discov-
  ered on the south branch of the Elizabeth River on October 6, 2010  tlvelY ordered to pay $66,402.41 in restltu-
                Photograph: U.S. Coast Guard                tion.
       Steven and Billy Avery operated  Sea Solutions, Inc.  In February 2010, Sea Solutions, Inc. pur-
chased a vessel known as M/V Snow Bird for the purpose of scrapping, with the knowledge that it contained
a quantity of petroleum products and other pollutants.  The defendants knew these waste products were on-
board the M/V Snow Bird and needed to be removed prior to scrapping, but they knowingly commenced
scrapping operations with the pollutants onboard.  Over the course of several months, witnesses complained
of pollutants emanating from the M/V Snow Bird.  In October of 2010, the  defendants caused a major spill
of oil, oily water, and other pollutants from the M/V Snow Bird into the Elizabeth River.  The cleanup op-
eration removed several thousand gallons of oily waste from the Elizabeth River and the shoreline at the
cost to the United States of over $66,000.
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                                                                                 EPA Bulletin July 2012 4

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 Former Coos Bay/North Bend Water Treatment Supervisor Pleads Guilty to and Sentenced for Falsi-
 fying Water Testing Results — On July 24, 2012, TAMMY
 YOUNG, of Coos Bay,  Oregon, pleaded guilty to making a
 false statement to a government agency. Young was sentenced
 to three years of probation and 100 hours of community service.
 Young was charged with making  a false statement on monthly
 monitoring reports to the Oregon Health  Authority (OHA), a
 felony charge. While serving as the Water Treatment Plant Su-
 pervisor  and Water  Quality Technician, Young  submitted
 monthly monitoring reports for drinking water which contained
 false test results for coliform bacteria. She was fired as a result
 of this conduct.  The OHA relies on the accuracy of information      Coos Bay - North Bend Water Board
 from water treatment plant supervisors to ensure that the water supplied by the Coos Bay/North Bend Public
 Water Board is in compliance with the Safe Drinking Water Act and is safe for the public to drink. Under
 the federal Safe Drinking  Water Act, which is administered and enforced by the OHA, along with EPA, the
 Coos Bay/North Bend Public Water Board must provide drinking water that meets standards to ensure that
 the water is safe for human consumption. Drinking water is tested for coliform bacteria, a bacteria naturally
 present in the environment, which  at certain levels, may indicate the presence  of other, more harmful bacte-
 ria. EPA establishes levels of coliform bacteria permitted in drinking water. Regular testing allows public
 water systems to monitor these levels and ensure that there are no safety concerns with the water supply and
 no health risks.  There is no indication that Young's actions caused any actual  harm to individuals who con-
 sumed drinking water from the plant.  This investigation was conducted by the EPA Criminal Investigation
 Division  with assistance  from the Oregon Health Authority  Center for Health Protection.  The case was
 prosecuted by the United States Attorney's Office for the District of Oregon.
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Philadelphia Plant Sentenced for Criminally Tampering its Wastewater Samples— On July 27, 2012,
NUPRO INDUSTRIES CORPORATION, located in Philadelphia, was sentenced to three years probation
and a $200,000 fine for criminally tampering with samples of the wastewater it was discharging into Phila-
delphia's sewer system. Nupro Industries Corporation, which manufactures oils and esters at its plant at East
Ontario and Bath Streets in Philadelphia, pleaded guilty on March 2, 2012, to criminally tampering with a
required monitoring method. Nupro's pretreatment permits with the city required Nupro to  monitor the pol-
lutants in its industrial wastewater by taking representative samples of its wastewater and submitting the sam-
ples for testing of specified pollutants, such as pH and ethylbenzene. From 2006 to June 2007, Nupro wa-
tered down the samples, making the samples non-representative, in order to dilute the pollutants and appear
to be in compliance with the pollutant limits under the permits. In addition to probation and the fine, the court
ordered Nupro to undertake a $25,000 community service  project as designated by the Philadelphia Water
Department, and they were ordered to implement an Environmental Compliance and Ethics Plan as a condi-
                               tion of probation. Under the Plan, Nupro agreed to address and correct its
                               environmental problems, to designate employees to be responsible for en-
                               vironmental issues and compliance at Nupro, and to annually train all of its
                               employees on  environmental compliance. Nupro was  further  ordered to
                               publish, in an appropriate trade journal and a local newspaper,  advertise-
                               ments describing  Nupro's conduct, conviction, and  sentence,  remedial
                               steps taken to  prevent reoccurrence, and to provide information to  other
                              | regulated entities about how to avoid similar prosecution.
                               Back to Top
Nupro Industries Corporation
                                                                                  EPA Bulletin July 2012  5

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Illinois Man Sentenced to 10 years in Federal Prison for Clean Air Act Violations involving Asbestos
On July 25, 2012, DUANE "BUTCH" O'MALLEY, I
was sentenced to 10 years in prison, the payment of ap-1
proximately $47,000 in restitution, and a $15,000 fine.
He was also sentenced to three years supervised release.
O'Malley was convicted by a federal jury on September |
26, 2011, for the illegal removal, handling and disposal
of asbestos from a Kankakee building in August 2009.
O'Malley  was charged  in June 2010 with five felony
violations  of the Clean  Air Act, along with Michael J.
Pinski, and James A.  Mikrut.  Pinski  entered a plea of
guilty on August 19, 2011, to one count of violation of
the Clean Air Act; Mikrut pled guilty on August  24,
2011, to five counts of violating the Act. Sentencing for  O'Malley and his workers filled these garbage bags with
Pinski and Mikrut has not yet been scheduled.  During  asbestos insulation they removed from pipes and dumped
                                                      them in an open field, resulting in soil contamination.
O Malley  s trial, which began on September 21, 2011,
the government presented evidence that O'Malley, owner and operator of Origin Fire Protection, was hired
by Pinski in August 2009 to remove asbestos-containing insulation from pipes in a five-story building that
was owned by Pinski  through his company, Dearborn Management, Inc.  Neither O'Malley nor anyone in
his company was trained to perform the asbestos removal work. O'Malley agreed to  remove the asbestos
insulation for an amount that was substantially less than a trained asbestos abatement contractor would have
charged to perform the work.  Furthermore, O'Malley arranged for Mikrut to recruit and oversee workers to
remove the asbestos.
       The government's evidence showed that various  provisions of the Clean Air Act and EPA regula-
tions were violated, including: failure to properly notify EPA; failure to have trained on-site representatives
present; failure to ensure the asbestos insulation was adequately wetted while it was being stripped and re-
moved; failure to mark vehicles used to transport the asbestos-containing waste material; and, failure to de-
posit the asbestos in a  waste disposal site for asbestos. Instead, the asbestos insulation was stripped from the
pipes while dry,  and then placed in more than 100 large, unlabeled plastic garbage bags, which were dumped
in an open field in Hopkins Park, resulting in asbestos contamination of the soil.   At the sentencing hearing,
the government presented evidence that the manner in which the asbestos had been removed from the build-
ing had exposed the workers  hired by O'Malley to dangerous asbestos-laden dust, which endangered their
health.
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                                                                                  EPA Bulletin July 2012  6

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Singapore Ship Engineers Sentenced to Crimes Related to Pollution From Cargo Ship Traveling to
Alabama— On July 26, 2012, two Singapore
ship engineers were sentenced for violations
of the Act to Prevent Pollution  from Ships.
Chief Engineer  PAYONGYUT  VONGVI-
CHUANKUL was sentenced to  six months
home  confinement, but was credited with
time  served for the 10 months  he was  de-
tained in Mobile, Alabama.  He was placed
on probation for a term of a year and ordered
to pay a $100 special  assessment.  No fine
was levied because he  has no ability to pay.
On the same day,  Second Engineer PAK-
POOM HANPRAP was  sentenced to one  Spool pipe used to connect the bilge system to the ballast system on the
                                           ship, which allowed the crew to bypass the Oil Water Separator and dis-
year  probation,  a $100  special  assessment,                   charge oily waste overboard.
and no fine.  Both were ordered to leave the
country in 14 days or less.  They discharged and caused the overboard discharge of oily bilge waste from the
M,V Gaurav Prem on multiple occasions as the vessel sailed from South Korea to Mobile in 2011.  The dis-
charges were not recorded in the vessel's oil record book as required.  The deliberate overboard discharges of
oily waste were  accomplished through the ship's fixed  bilge piping system and by using the ship's general
service pump in a manner that intentionally bypassed required pollution prevention equipment.
       Target Ship Management Pte. Ltd., operator of the M/V Gaurav Prem, pleaded guilty on May 30,
2012, to a violation of the Act to Prevent Pollution from Ships for failing to properly maintain an oil record
book as required by federal and international law, and for making material false statements during a U.S.
Coast Guard inspection of the ship at the port of Mobile in  September 2011. The company was sentenced to
pay a $1 million criminal fine along with a $200,000 community service payment to the National Fish &
Wildlife Foundation. Target was also sentenced to three years probation.  As a condition of the probation,
ships operated or managed by Target that will or may call on the United States, are required to submit an en-
vironmental compliance plan supervised by outside auditors and the court.
       The ship's captain, Prastana  Taohim, was convicted at a jury trial on May 17, 2012,  for obstructing
the Coast Guard's inspection for similar but unrelated charges.  At trial, it was found that Taohim ordered the
ship's chief officer to throw hundreds of plastic pipes into the ocean and not record the discharge in the
ship's garbage record book as required. Taohim then knowingly made the garbage record book with the de-
liberate omissions available during the Coast Guard inspection on September 21, 2011. The plastic pipes had
previously contained insecticide and were used to fumigate a grain shipment. The jury also found him guilty
                                               of obstruction of justice related to covering up the pollu-
                                               tion by creating a false and fictitious garbage log.  He is
                                               scheduled to be sentenced on August 15, 2012.  This in-
                                               vestigation was conducted by the U.S. Coast Guard In-
                                               vestigative Service and the U.S. Environmental Protec-
                                               tion Agency Criminal Investigation Division. Additional
                                              • assistance was provided by the Coast Guard Sector Mo-
                                             (bile and U.S. Coast Guard Eighth District Legal Office.
                                               The case was prosecuted by the Department of Justice's
                                               Environmental Crimes Section and the U.S. Attorney's
                                               Office for the Southern District of Alabama.
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                                               	EPA Bulletin July 2012  7
The M/V Gaurav Prem

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Greek Shipowners to Pay $1.2 Million Fine for Dumping Oil Wastes — On July 25, 2012, ODYSEA
                                            CARRIERS,  S.A., an Athens, Greece-based  shipping
                                            firm, was sentenced in federal court in the Eastern Dis-
                                            trict of Louisiana to pay a $1.2 million fine and be placed
                                            on three years probation after pleading guilty on March
                                            8, 2012 to illegally discharging oily waste into the ocean
                                            and covering up the illegal actions.  The charges stem
                                            from an investigation into the actions  of the M/V Poly-
                                            neos, a 37,623 gross ton ocean-going bulk carrier owned
                                            by Odysea, which docked at the Port of New Orleans on
                                            October  12, 2011. According to  court records,  engine
              The M/V Polyneos               room crew members used a hose to pump the contents of
the ship's bilge tank, bilge oil tank and sludge tank directly overboard from at least June  8, 2011.
       PEDRO GUERRERRO, chief engineer of the Polyneos, covered up the discharges by falsifying
the vessel's oil record book, where all such discharges are supposed to be accurately recorded. Guerrerro
also made false entries indicating an incinerator was used to burn the oil waste and sludge "with the intent
to conceal from Coast Guard authorities that dumping had occurred."  On February 15, 2012, Guerrerro
pled guilty to making and using a false document, the oil record book.  He was sentenced on May 2, 2012
to three years supervised probations and ordered to pay a $2,000 criminal fine.
       The $1.2 million fine includes a  $100,000 community  service payment to  the National  Fish and
Wildlife Foundation, which will be used in Louisiana.  Odysea also is required to implement an Environ-
mental Compliance Plan to ensure all of its ships comply with maritime environmental rules, and that the
company's employees, including ship crews, are properly trained in preventing  maritime pollution.  An
independent monitor will submit  reports to the court detailing Odysea's compliance  with its environ-
mental obligations during the three year probation period.
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                           Plea Agreements (Back to Quick Links)
 Barge Owner Pleads Guilty to Water Crimes
   The Davy Crockett, shown in an aerial view last March, was sur-
         rounded by a cofferdam and dismantled in place.
On July 12, 2012, BRET A. SIMPSON, owner of Prin-
          ciple Metals, LLC, pled guilty in federal dis-
          trict court for the Western District of Wash-
          ington to two criminal violations of the Clean
          Water Act,  specifically, failing  to report a
          discharge of oil, and unlawfully  discharging
          oil into the Columbia River.  Simpson admit-
          ted he was informed about oil that was left
          inside the Davy Crockett barge while he was
          conducting salvage operations, but he did not
          have the oil removed before workers started
          cutting up the metal barge. Failure to  report
          the offense is punishable by up to five years
          in prison; the unlawful discharge is punish-
          able by up to one year  in prison.  Sentencing
          is scheduled for October 12.
            When  the first oil  spill occurred in  De-
 cember 2010, Simpson failed to notify authorities and he failed to take any affirmative steps to monitor the
 vessel or to protect it from natural forces that could exacerbate the spill and  potentially cause additional
 structural damage.  Subsequent spills in January 2011 led U.S. Coast Guard investigators to identify the
 Davy Crockett as the  source and to initiate a federally funded cleanup effort. The Coast Guard ultimately
 spent eight months and approximately $20 million working with environmental authorities to clean up the
 oil spill and remove the derelict barge from the river.
       The Davy Crockett is a former U.S. Navy ship that was converted to a flat deck barge.   Simpson's
 company planned to cut it apart and sell the metal for scrap. He assembled a crew to do the job but made
 no arrangements to remove the fuel oil and diesel fuel from the vessel before the scrapping operation began.
 In December 2010, a member of the scrapping crew cut into a structural beam of the barge and the ship be-
 gan breaking apart and leaking oil.  Neither Simpson nor anyone with his company notified authorities
 about the leak.
       Simpson initially addressed the oil release by ceasing all scrapping operations, procuring a boom to
 limit the release, and directing an employee to monitor vessel conditions.  The employee did so for about a
 week before being relieved of his employment.  Simpson took no further steps to monitor the ship or to pro-
 tect it from further structural damage.  In January 2011, an accumulation of debris next to the barge forced
 it to move and additional oil was released.  The
 Coast Guard issued an administrative order to re-
 move any remaining  visible oil from  machinery
 spaces and deck tubes together with other salvage
 debris from  the vessel.   Simpson complied and
 authorities believed the barge no longer posed an
 environmental danger. However, on January 27,
 2011,  additional  oil was  released and state and
 federal  authorities  immediately  responded  in  an
 effort to limit environmental damage.
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                                               ^^^^^^^^^^^^^^^^^m

	EPA Bulletin July 2012 9

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 Louisiana Dry Cleaning Business Owner Pleads Guilty to Negligent Waste Water Discharge - On July
 31, 2012, JASON PREJEAN, of Lafayette, Louisiana, pleaded guilty in federal court on behalf of himself
 and ONE LOW  PRICE CLEANERS (OLPC) to violating a local  pre-treatment program by negligently
 causing and allowing the discharge of hazardous waste into a publicly owned treatment works or sewer sys-
 tem.  Prejean violated an approved local pre-treatment program maintained by Lafayette Utility System,
 which requires all users of the sewer system to obtain a permit to discharge industrial wastes into the utility's
 publicly owned treatment works. OLPC was never issued a permit to discharge any amounts of PERC into
 the sewer system.
       Prejean, owner of OLPC, admitted that he acted negligently in failing to ensure the proper and lawful
 disposal of waste waters containing PERC and that he failed to train OLPC  employees on the proper and
 lawful disposal of PERC waste.  Dry cleaners are required by law to contract with a permitted hazardous
 waste company to dispose of the PERC lawfully. Prejean also admitted that he had not used a disposal com-
 pany since February 2007.  Investigations conducted by EPA's Criminal Investigation Division and Louisi-
 ana Department of Environmental Quality revealed that from December 2007 through May 2009, PERC was
 being improperly  stored on-site and that OLPC and employees routinely poured PERC wastewaters down the
 toilet inside the store.  Due to misrepresentations by an  OLPC employee, agents did not discover that em-
 ployees had been  storing PERC in unapproved Rubbermaid containers  until May 28, 2009, the second day of
 an emergency response to detect and determine  the source of the hazardous fumes. During the emergency
 response and investigation on May 27  and 28, 2009, citizens  and employees of adjacent businesses were
 evacuated, and some were medically treated due to reported symptoms from the exposure of PERC fumes.
 Responders  from the Louisiana State Police Emergency Services Unit,  Louisiana Department of Environ-
 mental Quality, Louisiana Department of Health and Hospitals, the Lafayette Utility Service, and the U.S.
 Army National Guard 62nd Weapons of Mass Destruction Civil Support Team, arrived on scene and re-
 mained there for three days.  Traces of the hazardous substance, PERC, were located in adjacent businesses
 due to the fact that OLPC shared a common sewer system with these  businesses. Test results also revealed
 the presence of PERC at the junction in which sewer waters from OLPC enters the city sewer system.
 Back to Top
 Texas Refinery Admits of Negligently Releasing Hazardous Air Pollutants — On July 17, 2012, TEAM
                                                INDUSTRIAL SERVICES, INC. (Team),  which
                                                provided leak detection and repair services at a refin-
                                                ery  near Borger, Texas, admitted in federal district
                                                court for the Northern District of Texas that it negli-
                                                gently released hazardous pollutants into the ambient
                                                air, placing people in danger of death or serious bodily
                                                injury.  According to plea documents, Team employ-
                                                ees at the refinery knowingly failed to follow required
 protocols while  conducting emissions monitoring of certain refinery components. They also manipulated
 testing data to falsely represent emissions monitoring events that were not performed.  A Team supervisor
 knew the emissions monitoring data was false yet, along with another employee, they altered the emissions
 monitoring database to falsely represent emissions monitoring events to EPA and the Texas Commission on
 Environmental Quality.
       As part of its plea agreement, Team agreed to develop and implement an environmental compliance
 plan that specifically addresses its leak detection and reporting activities to achieve appropriate compliance
 with the Clean Air Act's leak detection and repair regulations. It also acknowledges that its facility in Bor-
 ger will  be  placed on EPA's list of violating facilities and will, therefore, be ineligible for  any federally
 funded contracts, grants, or loans, until it is removed from the list. No sentencing date has been set.
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	EPA Bulletin July 2012  10

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Asgard Associates Pleads Guilty to Illegal Hazardous Waste Storage —
On July 18, 2012, ASGARD  ASSOCIATES, LLC,  a Dela-
ware corporation, pleaded guilty in federal  district court for the
Southern District of California to unlawfully  storing hazardous
waste.   Asgard admitted responsibility for maintaining chemi-
cals and biological  agents in  a laboratory in San  Diego that
posed a threat of imminent and identifiable harm to the public
health and safety.
       The company knew that between January  26, 2010 and
March 18, 2010, numerous containers of chemicals were stored
at its laboratory in lieu of disposal, and that some  of the chemi-
cals (stored without a permit)  had the potential to pose a sub-
stantial  risk to human health and the environment.  Neverthe-
less, Asgard refused to provide funds for the disposal  of these
hazardous chemicals.  Because of this failure, the  San Diego
County  Department of Environmental Health Services (DEH)
spent  $8,693  conducting inspections and sampling  the chemi-
cals on May 6, 2010, and June 10, 2010. On August 13, 2010,
the U.S. EPA conducted  a  clean-up  (under the authority  of
Superfund), that included  over 2,500 containers  of hazardous
chemicals. These chemicals had to be "detonated" by the EPA
and the San Diego Fire Department Bomb  Squad as they were
too unstable for safe transport.  The direct costs of the clean-up
to EPA were $167,718.68.
       In its felony plea, Asgard Associates agreed to repay the
costs incurred by the EPA  and DEH and further agreed that an
employee, Michael Conrad, will perform 240 hours  of commu-
nity service. The plea is subject to final acceptance by the court
at sentencing.  Sentencing is scheduled for September 17, 2012.
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Abandoned chemicals found at Asgard laboratory
  Abandonedpetri dishes containing bacteria
                                                             Abandoned open chemicals and equipment
Correction for the June 2012 bulletin — It was mistakenly reported in the June 2012 bulletin that OHIO
VALLEY COAL COMPANY (OVCC) pleaded guilty on June 28, 2012 in federal district court for the
Southern District of Ohio to criminal violations of the Clean Water Act arising from two coal slurry release
incidents that polluted Captina Creek in Belmont County, Ohio.  However this plea agreement actually oc-
curred on July 13, 2012. We apologize for this error.
                                                                                 EPA Bulletin July 2012  11

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                    Indictments/Informations (Back to Quick Links)
Port Arthur Chemical and Environmental Services
 Former President of Texas Company Indicted for Employee Deaths and Environmental Violations -
                                                On July 18, 2012, PORT ARTHUR CHEMICAL
                                                AND   ENVIRONMENTAL  SERVICES,  LLC
                                                (PACES)  and its former president MATTHEW  L.
                                                BOWMAN were charged with  conspiracy to ille-
                                                gally transport hazardous materials, resulting in the
                                                deaths  of two employees, in an  indictment handed
                                                down by a federal grand jury in Beaumont, Texas,
                                                The 13  count indictment describes a scheme in which
                                                hazardous materials were transported  illegally  with
                                                false documents  and  without placards,  and where
                                                workers were not properly protected from exposure
                                                to hazardous gases.  The  exposure resulted in the
                                                deaths of two employees, who were truck drivers, at
 the PACES facility on Dec. 18, 2008, and April  14, 2009. Both deaths are attributed to exposure to hydro-
 gen sulfide.
       The defendants were charged with a conspiracy to violate the Hazardous Materials Transportation
 Uniform Safety Act (HMTUSA) and two counts of failure to  implement appropriate controls to protect em-
 ployees from exposure to hydrogen sulfide in violation of the Occupational  Safety and Health Administra-
 tion Act. They are also charged with transportation of hazardous materials without placards and with  false
 documents in violation of HMTUSA, violations  of the Resource Conservation and Recovery  Act and mak-
 ing false statements.
       According to the indictment, Bowman was presi-
 dent and owner of PACES,  located in Port Arthur,
 Texas, and CES Environmental Services (CES) located
 in Houston.  PACES  was  in  operation  from  approxi-
 mately November 2008  to November 2010, and was in
 the business of producing and selling caustic materials to
 paper mills. The production of caustic materials involved
 hydrogen sulfide, which is classified as a poisonous gas
 by HMTUSA.   According  to the National Institute for
 Occupational Safety and Health, hydrogen sulfide is an
 acute toxic substance that is the leading cause of sudden
 death in the workplace.  Employers are required by  the
 Occupational Safety and Health Administration (OSHA) to implement engineering and safety controls to
 prevent employees from  exposure above harmful limits.
       Bowman was responsible for, among other duties, approving and directing PACES production op-
 erations, the disposal of  hydrogen  sulfide wastewater, employee safety precautions, directing the transpor-
 tation of PACES wastewater, and determining what safety equipment could be purchased or maintained.
 Both PACES and CES have filed for bankruptcy. The conspiracy and substantive counts of the indictment
 each carry a maximum possible sentence of five years in prison and a fine of $250,000, and a $500,000
 maximum fine for the corporation.
       The allegations in the indictment are mere accusations and all persons are presumed innocent unless
 and until proven guilty beyond a reasonable doubt in a court of law.
 Back to Top                                                                    EPA Pub. 310-N-12-007
	EPA Bulletin July 2012  12
                                                          CES Environmental Services

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