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Multimedia Enforcement

Environmental harm often occurs across air, water and land. The Multimedia Enforcement Program fosters comprehensive approaches combining enforcement of all media in one case. This results in more effective overall management of environmental liability and is generally more cost-effective than bringing separate media-specific enforcement actions. 

The multimedia approach can be employed in the context of three basic types of enforcement actions:

The Multimedia Enforcement Program develops novel enforcement and compliance incentive approaches to address complex and emerging environmental problems.  It also “works backwards” from finding an environmental problem to reacting with targeted and streamlined enforcement approaches.

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Cross-Media Emissions - Vinyl Chloride

In 2002, EPA developed a multimedia chemical targeting approach utilizing public health and environmental data to identify potential candidates for enforcement.  Using this approach, EPA selected six chemicals, one of which was vinyl chloride (VC) an odorless gas. VC is an ozone precursor and known carcinogen that is also linked to neurological disorders.  To reduce the total amount of vinyl chloride entering the environment, EPA increased enforcement against the polyvinyl chloride manufacturing industry, which is responsible for the majority of vinyl chloride emissions in the United States. 

Enforcement and Compliance Assurance:  Polyvinyl Chloride (PVC) Manufacturing Plants

EPA is actively pursuing enforcement actions against PVC manufacturers under the Clean Air Act (CAA), the Resource Conservation and Recovery Act (RCRA), the Clean Water Act (CWA), and the Emergency Planning and Community Right-to-Know Act (EPCRA).  EPA’s enforcement activities in the PVC manufacturing sector focus on achieving compliance with environmental laws and on reducing the total amount of vinyl chloride entering the environment, regardless of the environmental pathway.  

Settlements with Major PVC Manufacturers Substantially Reduce Emissions of Carcinogen Vinyl Chloride and Increase Compliance

Civil enforcement settlements demonstrate the significant reductions that can be achieved by PVC manufacturers.  These settlements have reduced vinyl chloride air emissions by approximately 140,000 pounds per year and resolved alleged violations under the CAA, RCRA, and other environmental laws.

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Georgia Gulf Chemicals and Vinyls, LLC committed to perform corrective measures to prevent the discharge of up to 12,000 pounds of vinyl chloride per year from entering an unlined surface impoundment at its Aberdeen, Miss. polyvinyl chloride (PVC) manufacturing facility.  The consent decree also required Georgia Gulf to perform corrective measures at an estimated cost of $2,900,000. The requirements included installation of an air stripper to reduce volatile organic compounds (VOCs) by removing vinyl chloride from process wastewater.  The company resolved alleged violations of the RCRA, CAA, CWA, and EPCRA.  Georgia Gulf also will pay a civil penalty of $610,000 to be split evenly between the United States and the State of Mississippi.

Shintech Louisiana LLC was required to pay a $426,530 civil penalty to resolve alleged environmental violations at two of its plants in Addis, Louisiana, including failing to identify hazardous waste, keep records of its hazardous waste, and obtain the required approval to manage and store hazardous waste, and CAA reporting and record keeping.  Shintech corrected its processes after inspections of its facilities in 2004 and 2005.

Formosa Plastics Corporation entered into a Consent Decree to resolve alleged multimedia violations at its Delaware plant and to reduce 36,000 pounds of permitted vinyl chloride emissions, and up to 20,000 additional pounds through a unique incentive program.  Formosa paid a $450,000 civil penalty and will perform Supplemental Environmental Projects (SEPs) expected to cost $843,000.

Oxy Vinyls, LP, North America’s largest PVC resin supplier, committed to reduce vinyl chloride emissions by over 40,000 pounds per year and to resolve alleged multimedia violations.  Oxy paid a $140,000 federal civil penalty to be divided equally with the Louisville Metropolitan Air Pollution Control District and a $200,000 penalty to New Jersey for state-only violations.  Oxy will also spend $1,244,000 to implement several SEPs.

Occidental Chemical Corp. entered into an administrative settlement with EPA resolving alleged violations under multiple environmental laws at its Pottstown, Pennsylvania facility.  Occidental agreed to perform SEPs valued at $900,000 that include process changes and equipment upgrades to reduce vinyl chloride emissions by 52,000 pounds per year, and to reduce water usage.  Occidental also paid a $150,000 civil penalty.

Online Resources

Enforcement Alert newsletters inform the public and those regulated by environmental laws about important environmental enforcement issues, recent trends, and significant enforcement actions.  EPA Enforcement Reduces Threat from Polyvinyl Chloride Manufacturing Plants highlights recent enforcement actions in the polyvinyl chloride (PVC) manufacturing sector; describes common violations; and lists actions PVC manufacturers can take to reduce vinyl chloride emissions.  

EPA provides compliance assistance on a sector-by-sector basis in order to efficiently reach facilities with similar operations, processes, or practices.  EPA Compliance Assistance Centers address real-world issues faced by a specific industry or government sector.  The ChemAlliance Center  is a source for up-to-date information concerning the environmental regulations affecting the chemical industry. 

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