JP Morgan Chase Bank, N.A. (Board decision, September 19, 2017)

Plain-English summary

JP Morgan Chase Bank, N.A. resolved related Clean Air Act, Clean Water Act, EPCRA, and RCRA enforcement matters through a Consent Agreement with EPA. The Environmental Appeals Board incorporated the agreement into its Final Order and ratified it under 40 C.F.R. § 22.18(b)-(c). The Board ordered the respondent to comply with every term of the Consent Agreement, effective immediately. The order itself does not state the alleged violations or any penalty amount.

Decision snapshot

• Cited authorities: 40 C.F.R. § 22.18(b)-(c)
• Outcome: The Consent Agreement was incorporated and ratified, and the respondent was ordered to comply with its terms.
• Key point: One EAB Final Order can ratify a Consent Agreement resolving related Headquarters enforcement matters under several environmental statutes.

Full text (EPA EAB public release)

                     ENVIRONMENTAL APPEALS BOARD
               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                              WASHINGTON, D.C.

In re: )
)
JPMorgan Chase Bank, N.A. ) Docket Nos. CAA-HQ-2017-6001
) CWA-HQ-2017-6001
) EPCRA-HQ-2017-6001
) RCRA-HQ-2017-6001
)

                     FINAL ORDER

Pursuant to 40 C.F.R. § 22.18(b)-(c) of EPA's Consolidated Rules of Practice, the attached Consent Agreement resolving this matter is incorporated by reference into this Final Order and is hereby ratified.

The Respondent is ORDERED to comply with all terms of the Consent Agreement, effective immediately.

So ordered.

                     ENVIRONMENTAL APPEALS BOARD¹

Dated: September 19, 2017 By: Kathie A. Stein
Kathie A. Stein
Environmental Appeals Judge

¹ The three-member panel ratifying this matter is composed of Environmental Appeals Judges Aaron P. Avila, Kathie A. Stein, and Mary Beth Ward.

                     CERTIFICATE OF SERVICE

I certify that copies of the foregoing “Consent Agreement” and “Final Order,” in the matter of JPMorgan Chase, N.A., Docket Nos. CAA-HQ-2017-6001, CWA-HQ-2017-6001, EPCRA-HQ-2017-6001, and RCRA-HQ-2017-6001, were filed and copies of the same were sent to the following persons in the manner indicated:

By First Class Certified Mail/
Return Receipt Requested:

Susan V. Harris
Sidley Austin, LLP
One South Dearborn
Chicago, IL 60603

By Interoffice Mail:

Susan Shinkman, Director

Office of Civil Enforcement

Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency

1200 Pennsylvania Ave., NW

Mail Code 2241A

Washington, DC 20460

Dated: September 19, 2017 Annette Duncan
Secretary