Acuity Specialty Products Group Inc.
Acuity Specialty Products Group Inc. Acuity Specialty Products Group Inc.
discharged to the R.M. Clayton Reclamation Center POTW by running water from asink in the wastewater pre-treatment plant, and by running water through a hose intoa drain box outside the wastewater pre-treatment plant known as the "V-notch weir."Selective Sampling in Violation of ASP's Permit25. From in or about September 1998 until in or about November 2002, onnumerous occasions, Employee A directed Seaboard facility wastewater pre-treatmentplant employees to take steps to obtain samples of wastewater that were not"representative" samples of the facility's wastewater, as required by the Sewer UseOrdinance. These steps included backdating chain of custody forms for samples thatwere sent to and received from ASP's testing lab, filling sample bottles with mostlysanitary or tap wastewater, and taking grab samples (samples gathered instantly andimmediately) rather than composite samples (samples gathered over a 24-hour timeperiod) as required by the Permit.26. From on or about August 10, 1999 until on or about December 10 , 2002,on numerous occasions, Employee A knowingly reported false test results forphosphorous sampling on SMRs submitted to the City of Atlanta, in violation of thePermit.27. From in or about October 200 1 until in or about September 2002, onnumerous occasions, Employee A knowingly reported false flow data on SMRs8
submitted to the City of Atlanta.28. On or about April 4, 2000, Employee A knowingly failed to report thedischarge of approximately 10,000 gallons of sludge into the City of Atlanta sewersystem.29. On or about March 23, 200 2, Employee A knowingly failed to report toany authorities that acid product and caustic wastewater had been discharged into aditch at the Seaboard facility, in violation of ASP's Permit.30. From in or about June 2002 until on or about October 1, 2002, the exactdates being unknown, Employee A reported pH data on SMRs submitted to the Cityof Atlanta which was false because the pH probe was not functioning. It is not knownwhether the actual pH of the facility's wastewater exceeded the permit limits.31. On or about November 7, 2002, Employee A caused a garden hose to beused to dilute wastewater pre-treatment plant effluent in the V-Notch weir area of thewastewater pre-treatment plant, in order to prevent City of Atlanta personnel fromobtaining a representative sample of the facility's wastewater while the City personnelwere conducting monitoring at the facility.32. On or about the dates listed below, Defendant ASP, through EmployeeA, knowingly failed to report accurate phosphorus sampling results on the SMRssubmitted to the R.M. Clayton Reclamation Center POTW:9
- Page 2 and 3: GUILTY PLEA and PLEA AGREEMENTr!:ed
- Page 4 and 5: 1'1.up and the facts of this case,
- Page 6 and 7: the prov1s10ns set out mthe Complia
- Page 8 and 9: this Plea Agreement, the Government
- Page 10 and 11: CERTIFICATION OF ATTORNEY AND DEFEN
- Page 12 and 13: ATTACHMENT A
- Page 14 and 15: company, ASP. ASP is a Delaware cor
- Page 16 and 17: II10. The R.M. Clayton Reclamation
- Page 18 and 19: IIless than 25,000 gallons of waste
- Page 22 and 23: IIDateOctober 30, 200 1November 6,
- Page 24 and 25: ATTACHMENT B
- Page 26 and 27: purchased from other companies to m
- Page 28 and 29: eceiving a representative sample of
- Page 30 and 31: IHIconstruction on improvements to
- Page 32 and 33: X. Acuity represents to EPA that AS
- Page 39 and 40: allegations of Acuity's corporate i
- Page 41 and 42: (v). Schedule.After submission of t
- Page 43 and 44: (b) Vice President of Compliance/Du
- Page 45 and 46: ....12. Training.(a) Environmental
- Page 47 and 48: 5. that the training requirements d
- Page 49 and 50: I IG6. Freedom of InformationRespon
- Page 51 and 52: "during the term of this Agreement
- Page 53 and 54: 1111submissions to SOD through thei
- Page 55 and 56: ATTACHMENT C
- Page 57 and 58: EXHIBIT ARESOLUTIONSOFTHE BOARD OF
- Page 59 and 60: 2) WAIVER OF RIGHTS(a)The Governmen
- Page 61 and 62: 4) LIMITATION OF CHARGESThe United
- Page 63 and 64: 7) WAIVER OF APPEALIf the Court acc
- Page 65 and 66: In Open Court thisday of June, 2007
- Page 67: Ii iINFORMATION BELOW MUST BE TYPED
discharged to the R.M. Clayton Reclamation Center POTW by running water from asink in the wastewater pre-treatment plant, and by running water through a hose intoa drain box outside the wastewater pre-treatment plant known as the "V-notch weir."Selective Sampling in Violation of ASP's Permit25. From in or about September 1998 until in or about November 2002, onnumerous occasions, Employee A directed Seaboard facility wastewater pre-treatmentplant employees to take steps to obtain samples of wastewater that were not"representative" samples of the facility's wastewater, as required by the Sewer UseOrdinance. These steps included backdating chain of custody forms for samples thatwere sent to and received from ASP's testing lab, filling sample bottles with mostlysanitary or tap wastewater, and taking grab samples (samples gathered instantly andimmediately) rather than composite samples (samples gathered over a 24-hour timeperiod) as required by the Permit.26. From on or about August 10, 1999 until on or about December 10 , 2002,on numerous occasions, Employee A knowingly reported false test results forphosphorous sampling on SMRs submitted to the City of Atlanta, in violation of thePermit.27. From in or about October 200 1 until in or about September 2002, onnumerous occasions, Employee A knowingly reported false flow data on SMRs8
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