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National Enforcement Investigations Center (NEIC)
Case Results - Boasso America
Resource Conservation and Recovery Act Violations
Expert Toxicology Support
NEIC's Support:
•	Toxicological expertise
NEIC's Other Capabilities:
•	Forensics-based field
investigations and analytical
support under ISO/IEC:
17025, General
Requirements for the
Competence of Testing and
Calibration Laboratories
•	Statistical services
•	CAA, CWA. and EPCRA
expertise
•	Training
Background; Approximately 90 drums and containers were found abandoned in
February 2015 at several properties in Savannah, Georgia. These properties were
owned by CSX Railroad and the city of Savannah and were in a residential area. The
containers were found to have Boasso America (Boasso) labels. Boasso provides
transportation services for tank containers containing hazardous waste. The state
of Georgia's Environmental Protection Division emergency response program
conducted field assessment and sampling at a residential area where dumping had
occurred. Laboratory analysis of soil samples revealed naphthalene at
concentrations up to 750,000
parts per million (ppm) and liquid
waste with a pH of 14 pooled in an
area where children were known
to play.
NEIC's support: In early 2016,
EPA's Criminal Investigation
Division (CID) requested expert
toxicology support from NEIC to describe the potential for harm due to the toxic
effects of naphthalene and the hazards associated with corrosive liquids.
NEIC's toxicologist testified in a sentencing hearing for Raymond Mitchell (a subcontractor for the Boasso
wastewater treatment plant) in 2016, resulting in a nine-count sentence enhancement for the potential to cause
harm or serious bodily injury and one felony count of RCRA disposal without a permit. The toxicology testimony
indicated that the pH of the liquid waste found in a waste pit in a residential neighborhood could result in serious
burns and permanent tissue damage. Furthermore, the testimony demonstrated how the levels of naphthalene that
were measured in soil in the residential area could be lethal to a child if ingested. The expert testimony presented
by NEIC's toxicologist was also considered in the sentencing of the other defendants at later dates.
Enforcement results:
Boasso and six individuals plead guilty and received the following sentences:
•	$500,000 penalty
•	$58,052 in restitution
•	308 months of incarceration (cumulative for all defendants)
•	60 months of probation (cumulative for all defendants)
•	192 months of supervised release (cumulative for all defendants)
How to obtain ISIEIC's support
NEIC provides environmental forensics support for criminal and civil enforcement cases. If you would like more
information on NEIC or to request laboratory analysis, toxicological support, an investigation, technical assistance,
or training from NEIC, please contact us at neic project requests@epa.gov. You may also contact your regional
enforcement coordinator for more information on requesting NEIC's support on civil projects and EPA's CID for
support on criminal projects.
NEIC | Denver Federal Center, Building 25 | Denver, Colorado | 303.462.9000

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