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Press Release

United States and State of Wisconsin Reach Settlement with Container Life Cycle Management on Air Emissions and Waste Management Violations

For Immediate Release
Office of Public Affairs
Company Will Upgrade Facilities, Pay $1.6 Million Penalty

The United States and State of Wisconsin announced a settlement with Container Life Cycle Management LLC (CLCM) today that addresses Clean Air Act (CAA) and Resource Conservation and Recovery Act (RCRA) violations at the company’s container reconditioning facilities in the Milwaukee, Wisconsin, area. The company will pay a $1.6 million civil penalty to be split evenly between the United States and the State.

In a complaint filed with the proposed settlement, the United States alleged violations of the CAA, most notably at CLCM’s St. Francis facility, for failure to control emissions of volatile organic compounds as required by the EPA-approved Wisconsin state implementation plan. The complaint also alleges RCRA violations related to storage and handling of hazardous waste at the company’s facilities in St. Francis and Oak Creek, Wisconsin and its then-operating facility in Milwaukee, Wisconsin.

“Today’s settlement benefits public health and the environment by ensuring proper handling of hazardous wastes at Container Life Cycle Management’s container reconditioning facilities and will significantly limit harmful emissions of volatile organic compounds,” said Assistant Attorney General Todd Kim of the Justice Department’s Environment and Natural Resources Division.

“Today’s settlement will help us protect nearby residents and improve the region’s air quality,” said Acting Assistant Administrator Larry Starfield of the EPA’s Office of Enforcement and Compliance Assurance. “This is a good example of EPA working cooperatively with our state partners to ensure environmental compliance and secure emissions reductions.”

Highlights of the settlement include:

  • The company has installed and must continuously operate a regenerative thermal oxidizer to control air emissions of volatile organic compounds at the St. Francis facility. The company will also construct additional emissions capture systems within the facility and conduct performance testing.
  • At the Oak Creek facility, the company must install and continuously operate a new digital data recorder to record the temperature of the drum reclamation furnace afterburner. The company must maintain the afterburner temperature at or above 1,650 degrees and conduct performance testing.
  • The company must implement a container management plan, or CMP, for a two-year period established by the consent decree. The CMP provides for storage of heavy and non-empty containers in RCRA-compliant hazardous waste storage areas. Certain reporting requirements continue beyond the initial two-year period.

The proposed settlement is subject to a 30-day public comment period and final court approval. To view the consent decree or to submit a comment, visit

Updated April 5, 2024

Environmental Justice
Press Release Number: 22-1278