BP to Spend More Than $400 Million to Resolve Clean Air Act Violations


The EPA and the US Department of Justice (DOJ) announced that BP North America Inc., has agreed to pay an $8 million penalty and invest more than $400 million to install state-of-the-art pollution controls and cut emissions from BP’s petroleum refinery in Whiting, Indiana. When fully implemented, the agreement is expected to reduce harmful air pollution that can cause respiratory problems such as asthma and are significant contributors to acid rain, smog, and haze, by more than 4,000 tons per year.

“Today’s settlement will protect the residents of northwestern Indiana from harmful air pollution by requiring state-of-the-art pollution controls,” said Cynthia Giles, assistant administrator for EPA’s Office of Enforcement and Compliance Assurance (OECA). “BP’s agreement to install fenceline monitoring will also ensure that residents have access to critical information about pollution that may be affecting their community.”

“In this case, BP North America has not lived up to all of its obligations under an earlier settlement agreement and has committed new violations of the Clean Air Act (CAA) at its Whiting refinery in Indiana,” said Ignacia S. Moreno, Assistant Attorney General for the Environment and Natural Resources Division of the DOJ. “This settlement secures a significant penalty, requires state-of-the-art controls, and is a fair and just resolution that will address BP’s violations. We will continue to hold BP accountable and ensure that it complies with the nation’s environmental laws.”

The complaint alleges violations of CAA requirements at the Whiting refinery in connection with construction and expansion of the Whiting Refinery, as well as violations of a 2001 consent decree with the company that covered all of BP’s refineries and was entered into as part of EPA’s Petroleum Refinery Initiative.

This settlement will lead to the installation of innovative pollution controls on the largest sources of emissions at the Whiting refinery, including extensive new controls on the refinery’s flaring devices, which are used to burn-off waste gases. The more waste gases sent to a flare, and the less efficient the flare is when burning those gases, the more pollution that will occur. Under the settlement, BP will install new equipment that will limit the amount of waste gas sent to flaring devices in the first place, as well as implement innovative, cutting-edge controls to ensure proper combustion efficiency for any gases that are burned in a flaring device. The requirements, similar to those included in a recent settlement with Marathon Petroleum Corp., are part of EPA’s national effort to reduce emissions from flares at refineries, petrochemical, and chemical plants.

In addition to the controls on the refinery’s flares, the settlement will also result in reduced emissions by imposing some of the lowest emission limits in refinery settlements to date, enhancing controls on wastewater containing benzene and providing for an enhanced leak detection and repair program. The settlement also requires the Whiting refinery to spend $9.5 million on projects at the refinery to reduce the emissions of greenhouse gases (GHGs).

BP will perform a supplemental environmental project in which they will install, operate, and maintain a $2 million fenceline emission monitoring system at the Whiting refinery and will make the data collected available to the public by posting the information on a publicly-accessible website. Fenceline monitors will continuously monitor benzene, toluene, pentane, hexane, sulfur dioxide, hydrogen sulfide, and all compounds containing reduced sulfur.

BP Products North America Inc., headquartered in Warrenville, Illinois, engages in the exploration, development, production, and marketing of oil and natural gas, and additionally operates petroleum refineries in California, Indiana, Ohio, Texas, and Washington. BP North America Inc., is a subsidiary of BP p.l.c., headquartered in London, England. The Whiting Refinery has a refining capacity of approximately 405,000 barrels per day and is the 6th largest refinery in the US.

The consent decree is subject to a 30-day public comment period and final court approval.

Baltimore RCRA, DOT, and IATA/IMO Training

Register for Hazardous Waste Management: The Complete Course (RCRA) and DOT Hazardous Materials Training: The Complete Course, in Baltimore, Maryland, from June 5–7 and save $100. Transportation of Dangerous Goods: Compliance with IATA and IMO Regulations will be offered in Baltimore on June 8. To take advantage of the discount offer for the Baltimore RCRA and DOT combination, or to register for any of the Baltimore training courses, click here or call 1-800-537-2372.

Baton Rouge RCRA and DOT Training

Register for Hazardous Waste Management: The Complete Course (RCRA) and DOT Hazardous Materials Training: The Complete Course, in Baton Rouge, Louisiana, from June 12–14 and save $100. To take advantage of this offer, click here or call 1-800-537-2372.

Chattanooga RCRA and DOT Training

Register for Hazardous Waste Management: The Complete Course (RCRA) and DOT Hazardous Materials Training: The Complete Course, in Chattanooga, Tennessee, from June 19–21 and save $100. To take advantage of this offer, click here or call 1-800-537-2372.

How to Prepare for OSHA’s Globally Harmonized Hazard Communication Standard (GHS)

OSHA has issued a final rule revising its Hazard Communication Standard, aligning it with the United Nations’ globally harmonized system (GHS) for the classification and labeling of hazardous chemicals. This means that virtually every product label, material safety data sheet (now called “safety data sheet” or SDS), and written hazard communication plan must be revised to meet the new standard. Worker training must be updated so that workers can recognize and understand the symbols and pictograms on the new labels as well as the new hazard statements and precautions on SDSs.

Environmental Resource Center is offering webcast training for you to learn how the new rule differs from current requirements, how to implement the changes, and when the changes must be implemented. Register for an upcoming webcast on How to Prepare for OSHA’s Globally Harmonized Hazard Communication Standard (GHS) offered on the following dates:

  • June 26
  • July 18
  • August 15
  • October 2

Public Health Groups Move to Enter Fight Over Toxic Chemical

One of the largest labor organizations in the US, a leading environmental advocacy group, and one of the top physicians in occupational medicine filed legal papers late recently, aimed at making sure government can alert the American public to the potential dangers of styrene, a chemical used extensively in the manufacture of plastics, as well as boats, cars, bathtubs, and products made with rubber, such as tires and conveyer belts. The groups filed a motion to intervene, seeking to help defend the US Department of Health and Human Services’ (HHS) listing of styrene as “reasonably anticipated to be a human carcinogen.” The motion is in response to a chemical industry lawsuit attempting to force the agency to withdraw the styrene warning.

“This case is about the public’s right to have scientifically sound information on the link between styrene exposure and cancer,” said Marianne Engelman Lado, Earthjustice attorney representing the groups. “Styrene is a dangerous chemical that is all around us because of its widespread use in plastics manufacturing. It’s clear that industry is trying to prevent people from getting scientific information about this toxic chemical and we intend to make sure government can inform the public of the risk of styrene, as well as the potential dangers of other chemicals.”

Styrene has long been suspected of being harmful to human health. The listing of styrene by the HHS came after seven years of scientific review, vetting by multiple panels of experts, and numerous rounds of public comment. HHS is the US government’s principal agency for protecting the health of all Americans.

In addition to the HHS listing, the EPA regulates styrene as a Hazardous Air Pollutant (HAP) and has described styrene to be a suspected toxin to the gastrointestinal tract, kidney, and respiratory system, among others, and the International Agency for Research on Cancer (IARC) and World Health Organization (WHO) have for years considered styrene to be possibly carcinogenic to humans. Styrene is used to manufacture many common household products such as plastic packaging and disposable cups, and is found in building insulation, automobile parts, floor waxes and polishes, and personal care products among other common items. It is also approved for use in containers and food-contact materials, and is an FDA-approved synthetic flavoring in ice cream and candy.

“Thousands of our members are exposed to styrene on the job,” said Michael Wright, Director of Health, Safety, and Environment at United Steelworkers. “They have a right to know the truth—that our government has found that styrene exposures may lead to cancer in humans—and this listing makes it publicly known. It’s time for the chemical industry to stop denying that truth, and instead put its resources into ensuring that styrene and other toxic chemicals are used as safely as possible.”

Under the Public Health Service Act (PHSA), HHS has delegated the responsibility of publishing a biennial report on carcinogens to the National Toxicology Program (NTP), a part of the National Institutes of Health (NIH). In its most recent Report on Carcinogens (ROC), released on June 10, 2011, NTP listed the chemical styrene as reasonably anticipated to be a human carcinogen based on evidence from studies in both humans and animals.

Immediately following the listing, the Styrene Information and Research Center (SIRC), an industry association, and Dart Container Corporation, the world’s largest manufacturer of polystyrene cups, sued HHS, seeking to compel HHS to withdraw the styrene listing. SIRC member companies, which include Dart, are involved in the manufacturing and processing of styrene or in the fabrication of styrene-based products.

“Should this industry lawsuit be successful, it will prevent workers, consumers, and members of the public who may be exposed to styrene, as well as health professionals, from receiving authoritative information about styrene and its impacts on human health,” said Richard Denison, Senior Scientist at the Environmental Defense Fund (EDF) and an expert on chemical safety. “It could have a major chilling effect on the ability of government agencies to carry out their responsibilities to identify toxic chemicals and provide the public with potentially life-saving information about them.”

The motion, which was prepared by the public interest law firm Earthjustice, is filed on behalf of the United Steelworkers, which represents workers who are especially exposed to styrene at their workplaces, and EDF.

“We are compelled to take decisive action here to help the government vigorously defend its styrene listing,” said Earthjustice’s Marianne Engelman Lado. “The government must be able to continue its pursuit of sound science and disclose vital conclusions about the impacts of toxics on the public health. Workers, mothers, and their children, all of us have a right to know, so that we may make the most informed and healthy choices in our daily lives.”

EPA Releases White Paper with Option for SO2 Implementation

EPA released a white paper, entitled Implementation of the 2010 Primary 1-Hour SO2 NAAQS, that contains options for implementation of the primary sulfur dioxide (SO2) National Ambient Air Quality Standard (NAAQS). Provided in order to facilitate discussion during the agency’s upcoming stakeholder meetings, which are scheduled in May 30–June 1, 2012, in Research Triangle Park, North Carolina, the white paper identifies options for determining whether air quality meets the SO2 NAAQS and evaluate possibilities for requiring the use of ambient air monitoring and/or modeling for this purpose. The white paper also solicits input regarding ways of implementing a final approach. The state/local/tribal SO2 stakeholder session is scheduled for May 31, 2012. EPA will accept written comments on the white paper through June 22, 2012.

EPA Advises Facility Operators to Minimize Releases During Hazardous Weather Events

As hurricane season approaches, EPA is issuing a Hazardous Weather Release Prevention and Reporting alert to remind facility operators of certain regulations that require minimization of chemical releases during process shutdown operations. This alert is designed to increase awareness among facility operators about their obligation to operate facilities safely and report chemical releases in a timely manner. The alert and requirements are available at

The alert specifies operational release minimization requirements and clarifies reporting requirements, including exemptions. Unlike some natural disasters, the onset of a hurricane is predictable and allows for early preparations to lessen its effect on a facility. Before hurricane force winds and associated storm surge flooding damage industrial processes, the alert recommends that operators take preventive action by safely shutting down processes or otherwise operate safely under emergency procedures.

In the event of a hazardous weather incident, please visit EPA’s Natural Disasters website for updated emergency information.

Heat-Related US Deaths Projected to Rise 150,000 by Century’s End Due to Climate Change

More than 150,000 additional Americans could die by the end of this century due to excessive heat caused by climate change, according to a detailed analysis of peer-reviewed scientific data by the Natural Resources Defense Council (NRDC).

The Killer Summer Heat report projects heat-related death toll through the end of the 21st century in the most populated US cities. The three with the highest number of total estimated heat-related deaths through 2099 are: Louisville, Kentucky (19,000 deaths); Detroit, Michigan (17,900); and Cleveland, Ohio (16,600), according to the report.

Other cities’ estimated death tolls through the end of the century include: Baltimore, Maryland (2,900 deaths); Boston, Massachusetts (5,700 deaths); Chicago, Illinois (6,400 deaths); Columbus, Ohio (6,000 deaths); Denver, Colorado (3,500 deaths); Los Angeles, California (1,200 deaths); Minneapolis, Minnesota (7,500 deaths); Philadelphia, Pennsylvania (700 deaths); Pittsburgh, Pennsylvania (1,200 deaths); Providence, Rhode Island (2,000 deaths); St. Louis, Missouri (5,600 deaths); Washington, District of Columbia (3,000 deaths).

The projected deaths are based on the widely-used assumption that carbon pollution will steadily increase in the absence of effective new policies, more than doubling the levels seen today by the end of the century.

“This is a wake-up call. Climate change has a number of real life-and-death consequences. One of which is that as carbon pollution continues to grow, climate change is only going to increase the number of dangerously hot days each summer, leading to a dramatic increase in the number of lives lost,” said Dan Lashof, director of NRDC’s climate and clean air program. “To prevent the health impacts of climate change from getting even worse, we need to establish a comprehensive program to reduce heat-trapping pollution from all sources, by building on the EPA’s proposals to limit carbon pollution from new power plants and cars.”

The kinds of consequences of climate change highlighted in NRDC’s report are already evident:

  • At least 42 states saw record daytime highs in the summer of 2011 and 49 states saw record high nighttime temperatures, according to the National Oceanographic and Atmospheric Administration (NOAA).
  • Health impacts spike during excessive heat events. For example, California was hit by deadly heat waves in 2006, causing during a two-week period 655 deaths, 1,620 excess hospitalizations, and more than 16,000 additional emergency room visits occurred, resulting in nearly $5.4 billion in costs. During a record-setting heat wave in 1995, Chicago suffered over 700 additional heat-related deaths.

The elderly and young children face bigger risks than most, according to the report.

“Our research shows that rising temperatures could cause five times the number of Excessive Heat Event (EHE) days by mid-century and eight-times the number by century’s end,” said Dr. Larry Kalkstein, research professor of geography and regional studies at the University of Miami. “These hotter days have a real human cost.”

The risks to public health are greatest when high temperatures and certain weather conditions combine to cause EHE days. EHE days occur when a location’s temperature, dew point temperature cloud cover, wind speed, and surface atmospheric pressure throughout the day combine to cause or contribute to heat-related deaths in that location.

NRDC based this analysis on two peer-reviewed studies co-authored by Kalkstein, one of which was published in the American Meteorological Society’s journal Weather, Climate, and Society, and the other published in Natural Hazards.

On May 24th, the dangers of carbon pollution were the subject of EPA public hearings on its proposal to limit carbon pollution from new power plants. The EPA is taking public comment on the proposal through June 25th. The proposal is the federal government’s first step toward setting limits for industrial carbon sources.

The proposal is a major step toward protecting public health from the consequences of climate change driven by carbon pollution. Pollution from existing power plants, refineries, and other sources will need to be addressed as well, according to NRDC.

Mineral Park, Inc. Fined $1.3 Million for Operating Without Air Permits

The Arizona Department of Environmental Quality (ADEQ) and Arizona Attorney General’s Office have announced that Mineral Park, Inc., (MPI) a subsidiary of Mercator Minerals of Canada, has agreed to a $1.3 million penalty in a consent judgment to resolve numerous air quality violations that occurred beginning in 2007.

After complaints of excessive dust in April 2009, ADEQ inspectors found that MPI was operating a large copper and molybdenum mine northwest of Kingman, Arizona, without the required permits. ADEQ inspectors observed several pieces of industrial mining equipment in operation, including copper and molybdenum mills, crushing systems, and ore conveyor transport systems.

ADEQ’s investigation determined that MPI began construction of the facility about April 2007. Because of the mine’s remote location, ADEQ only became aware of MPI’s activities after the dust complaints were received.

ADEQ issued a Notice of Violation (NOV) to MPI in July 2009 for constructing and operating the facility without a permit. After requesting and receiving additional information from MPI, ADEQ determined that the violation was more severe and in March 2010, issued a superseding NOV citing the facility for beginning construction and operating a new major source without a permit.

During the course of its investigation, ADEQ also discovered record-keeping violations, violations of hours of operation limitations, malfunctioning pollution controls, and excessive daily use of explosive materials. MPI ultimately remedied the air quality violations, including obtaining an air quality permit, and returned to compliance in July 2011.

According to its website, Mineral Park Mine is one of the largest milling operations of copper and molybdenum in North America with an estimated production life of 23 years. MPI also operates a solvent extraction/electro-winning system for copper extraction at the Mineral Park Mine site.

The consent judgment is subject to court approval.

Cedyco Corporation Pleads Guilty to Unlawful Discharges of Oil

A Delaware company has pleaded guilty to negligently discharging oil into the bayous of Jefferson Parish, Louisiana, the DOJ announced.

Cedyco Corporation, headquartered in Houston, Texas, pleaded guilty to three counts of violating the Federal Water Pollution Control Act (Clean Water Act). The Clean Water Act (CWA) makes it a misdemeanor to negligently discharge harmful quantities of oil into navigable waters of the US.

According to the plea agreement, Cedyco agreed to pay a criminal fine of $557,000. All of the fine money will be directed to the Oil Spill Liability Trust Fund to aid the US Coast Guard (USCG) in responding to future oil spills. Additionally, Cedyco also agreed to cease operations and divest itself of all hydrocarbon business interests in the state of Louisiana.

“Cedyco is being held accountable for its neglectful operations and poor management, which repeatedly resulted in illegal discharges of oil into the sensitive Louisiana bayou,” said Ignacia S. Moreno, Assistant Attorney General for the Environment and Natural Resources Division at the DOJ. “Those who are permitted to develop energy resources in proximity to delicate ecosystems must do so in a sound and responsible manner or they will be held accountable for violations of the law.”

Cedyco owned and operated several hydrocarbon facilities, including fixed barges, platforms, and wells, in the brackish bayous of South Louisiana. As a general matter, Cedyco’s facilities were poorly maintained and operated without plans and permits required by regulations issued by the Louisiana Department of Environmental Quality (LDEQ) as administrator of the federal CWA. Cedyco’s negligent operation and poor maintenance of three of its facilities in Jefferson Parish led to harmful discharges of oil into the navigable waters of the US. The three facilities are the tank battery known as the Bayou St. Denis facility, the production and storage facility known as the Bayou Dupont facility, and the production well adjacent to the Bayou Dupont facility known as Well #10. Each facility will be addressed in turn. Filed photo exhibits are available at the USCG website.

Cedyco’s Bayou St. Denis facility was a tank battery located south of the Barataria Waterway. A May 29, 2008, joint inspection by the USCG and LDEQ revealed that the facility was storing oil without the required Facility Response Plan (FRP), Spill Prevention and Control Plan (SPCC Plan), and LDEQ permit as required under CWA regulations. The condition of the facility was extremely poor with corroded pipes and spilled oil on the deck.

On June 15, 2008, enough oil was leaking from the facility that a sheen was visible on the surface of the water. A fisherman reported this sheen to the USCG, and a subsequent site visit by LDEQ on June 20, 2008, confirmed that oil was leaking into the adjacent waterway from the facility’s outfalls.

Cedyco’s Bayou Dupont facility is an oil storage and production platform located to the northeast of Bayou St. Denis, close to the Plaquemines Parish line. From February 18, 2008, to May 19, 2008, Cedyco operated this facility without a FRP, SPCC Plan, and LDEQ permit. A joint USCG and LDEQ inspection on February 19, 2008, revealed that the facility was in extremely poor condition with pools of oily water and emulsified oil on the deck, as well as ample evidence of extensive corrosion and leaks. The required spill response equipment was either missing or defective. For example, an absorbent boom meant to soak up oil spills had a plant growing out of it. During rain events that took place from February 19, 2008, through May 18, 2008, the deck oil made its way unimpeded into the bayou through unfiltered outfalls and cracks in the deck and containment structures. The sources of this oil were not only chronic leaks and occasional spills, but at times resulted from acute events such as the leak from the slop oil tank that occurred on May 18, 2008. The May 18 slop oil tank spill was observed by an LDEQ inspector who took photographs at the scene. During the charged period, the quantity of oil that was present on the deck of Bayou Dupont facility was sufficient to cause a sheen when rain caused the oil to wash into the adjacent waterway.

Cedyco’s Well #10 is located in an area of bayou adjacent to the Bayou Dupont facility. Cedyco did not properly maintain Well #10, and as a result of that negligence, the well began to leak on or about May 17, 2008. The leak continued for at least two days. Before it was contained with boom, the leak resulted in an oily sheen that was detected as far as two miles downstream from the well. The leaking oil also resulted in an emulsion being deposited on the adjacent shoreline.

The court set a sentencing date for Cedyco on August 15, 2012.

Oregon Cheese Processing Company Penalized for Failing to Report Ammonia Release

Columbia River Processing, Inc., failed to report an anhydrous ammonia release at its Boardman, Oregon, cheese processing facility in June 2008. The company has agreed to a settlement with the EPA that includes a $42,435 penalty.

On June 30, 2008, an electrical storm caused power surges that disrupted the computers and compressors that control the ammonia system at the facility. The computer failure caused a pressure relief valve to open, releasing nearly 2,500 lb of ammonia into the environment, according to the EPA settlement. Columbia River Processing failed to immediately notify local and state agencies about the release. No injuries were reported at the time of the incident.

According to Wally Moon, EPA Preparedness and Prevention Unit Manager in Seattle, these cases are about protecting workers, emergency responders, and the community.

Ammonia is a pungent, toxic gas that attacks skin, eyes, throat, and lungs and can cause serious injury or death. The ammonia release and the failure to notify appropriate agencies are violations of the federal Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and the Emergency Planning and Community Right-to-Know Act (EPCRA).

Waste Tire Transporter Arrested on Waste Tire Fund Violations

Investigators within the Criminal Investigation Division of the Louisiana Department of Environmental Quality (LDEQ) arrested a waste tire transporter on numerous felony counts related to the Louisiana Waste Tire Management Fund.

Rakeim Senegal, of Church Point, Louisiana, a waste tire transporter employed by Reds Transport, is being charged with 58 counts of forgery; 58 counts of filing a false public record; one count of theft of approximately $7,715; and one count of Waste Tire Fund fraud greater than $500. Senegal allegedly inflated the number of eligible tires and/or forged the names of legitimate tire generators on manifests so that he could be reimbursed by Colt Tire, a waste tire processor. Senegal is the son of Majella Green, a waste transporter who was recently arrested by DEQ–CID on the same charges.

If convicted of the crime of forgery, Senegal faces possible imprisonment for not more than ten years with or without hard labor, or a fine of not more than $5,000, or both per count. If convicted of the crime of filing false public records, Senegal faces possible imprisonment for not more than five years with or without hard labor, or a fine of not more than $5,000, or both per count. If convicted of the crime of theft, each faces possible imprisonment for not more than ten years with or without hard labor, or a fine of not more than $3,000, or both. If convicted of the crime of Waste Tire Fund Fraud and the fraudulent taking amounts to a value of five hundred dollars or more, Senegal faces imprisonment, with or without hard labor, for not more than ten years, or may be fined not more than three thousand dollars, or both.

Portland Property Management Company Cited for Violations of Federal Lead Rules

American Property Management (APM) of Portland, Oregon, will pay a penalty for alleged violations of the federal Lead Disclosure Rule, according to a settlement with the federal government. The EPA and US Department of Housing and Urban Development (HUD) announced the settlement, while urging landlords and property owners to inform people of potential risks from lead.

APM leases properties in Portland, Oregon. According to EPA and HUD inspectors, from 2007–2010, APM leased 35 units and failed to produce records showing they notified tenants about the potential presence of lead paint and lead–based paint hazards, as required by the Lead Disclosure Rule. The EPA and HUD requested the records during an inspection in 2010. APM will pay a $10,000 penalty.

The Lead Disclosure Rule requires landlords, property management companies, and sellers to inform potential lessees and purchasers of the presence of lead–based paint and lead–based paint hazards in pre–1978 housing. They must also provide the purchaser or lessee with a copy of the Lead Hazard Information Pamphlet, Protect Your Family from Lead in Your Home before entering into any lease or sales agreement, and keep records showing they have met the federal requirements.

Lead from paint, dust, and soil can be dangerous if not managed properly. Lead exposure can harm young children and babies even before they are born. People can get lead in their bodies by breathing or swallowing lead dust, or by eating soil or paint chips containing lead.

Environmental News Links

EPA Considers New Pharmaceutical Waste Rules

Higher Levels of Flame Retardants Found in Minority Children

Ohio Doctors Can’t Reveal Drilling Chemicals to Public

Ban on Plastic Bags at Los Angeles Markets is Approved

40-Year Air Force Fuel Spill Threatens Albuquerque’s Water

G8: Leaders Open Up Vital New Front in the Battle to Control Global Warming

Superhero Saves the Day—and the Environment

NATO’s Toxic Legacy: Billions Needed to Ameliorate Afghanistan’s Environmental Damage

Man Allegedly Dumped Thousands of Gallons of Hazardous Waste in New York Waterway

3M Plan to Import Hazardous Waste to Incinerate Won’t Need Environmental Review

Waste Hauler Contrite as He Avoids Prison in Forgery

White House Blocking EPA Efforts to Issue Rules on Nanomaterials, Advocates Say

Trivia Question of the Week

Other than the agreement with the Organization for Economic Cooperation and Development (OECD) and being a signatory to the Basel Convention, the US has individual international hazardous waste agreements with which of the following countries?
a. Canada and Mexico
b. Costa Rica
c. Malaysia and the Philippines
d. All of the above