Dyno Nobel Inc.
Outcome
Dyno Nobel agreed to pay $2,900,000 civil penalty and eliminate high-strength wastewater discharges, remediate soil contamination, and overhaul stormwater management at its Carthage and Louisiana, Missouri facilities, resolving CWA violations for discharging ammonia, nitrate, nitroglycerin, and other pollutants into Center Creek and the Mississippi River above permitted limits.
Details
Dyno Nobel Inc. — CWA, RCRA, and EPCRA Violations at Missouri Explosives Facility (2020)
Outcome: Dyno Nobel Inc. entered a consent decree requiring remediation of Clean Water Act, RCRA hazardous waste, and EPCRA violations at its Carthage, Missouri explosives manufacturing facility, resolving violations spanning three separate environmental statutes at the facility.
Dyno Nobel Inc., a commercial explosives manufacturer operating a production facility in Carthage, Jasper County, Missouri, faced enforcement action across three separate federal environmental programs at the same facility. The violations included Clean Water Act permit violations related to wastewater discharge at the manufacturing site, Resource Conservation and Recovery Act (RCRA) hazardous waste management violations related to the handling and storage of hazardous waste at the explosives manufacturing facility, and Emergency Planning and Community Right-to-Know Act (EPCRA) violations related to anhydrous ammonia storage and release reporting requirements.
The consent decree, entered February 27, 2020, required Dyno Nobel to address all three violation categories through a unified compliance program. The EPCRA violations specifically related to requirements for facilities storing quantities of anhydrous ammonia above EPCRA reporting thresholds to submit annual Tier II chemical inventory reports and to report accidental releases of extremely hazardous substances — requirements that the facility failed to fully satisfy.
The case is representative of a pattern seen at small to mid-size chemical manufacturing and specialty industrial operations: compliance attention focused on primary production permits (in this case, likely related to explosives manufacturing regulatory requirements) while ancillary environmental programs — wastewater discharge monitoring, hazardous waste management, and chemical inventory reporting — receive inadequate attention. The multi-statute enforcement outcome reflects what happens when these program areas are not actively managed within an integrated compliance system.
Primary Source: Dyno Nobel Inc. Missouri Settlement | US EPA
How Crucible Prevents This
Dyno Nobel's multi-statute violation pattern — simultaneous CWA, RCRA, and EPCRA violations — illustrates the consequence of siloed compliance management at a facility handling both hazardous waste and extremely hazardous substances. Crucible's cross-statute compliance calendar integrating RCRA hazardous waste management requirements, CWA discharge monitoring, and EPCRA Tier II reporting obligations in a single system would have surfaced the simultaneous gaps that created exposure across three enforcement programs. The EPCRA anhydrous ammonia reporting obligation — a quantitative threshold trigger — is exactly the type of deadline that a compliance calendar prevents missing.
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