March 09, 2020
EPA published the National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule (NPDES eRule
) on 22 October 2015. The 2015 rule required EPA and states to modernize Clean Water Act (CWA) reporting. The NPDES eRule included a phased implementation schedule. In the February 28 Federal Register
, EPA has proposed a postponement of the compliance deadlines for Phase 2 implementation by three years (to December 21, 2023) and to provide states with additional flexibility to request additional time.
EPA also proposed changes to the NPDES eRule that would clarify existing requirements and eliminate some duplicative or outdated reporting requirements. According to the Agency, these changes are designed to save the NPDES authorized programs considerable resources, make reporting easier for NPDES-regulated entities, streamline permit renewals, ensure full exchange of NPDES program data between states and EPA, enhance public transparency, improve environmental decision-making, and protect human health and the environment.
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Curtis Technology, Inc. Admitted to Hazardous Waste Violations
Curtis Technology, Inc., a San Diego firm that makes specialized coatings, pleaded guilty in federal court yesterday, admitting that the company illegally transported hazardous waste from its facility without a manifest. In pleading guilty, Curtis Technology admitted that it conducted metal finishing operations at its location on Sorrento Valley Road, which generated various wastes, including ferric chloride, alkaline, waste filter cake, solvents and other chemicals.
The company admitted that between December 12, 2015 and August 22, 2019, CTI owner Alex Jvirblis (deceased) and a maintenance employee transported chemicals, including waste ferric chloride, waste filter cake, waste alkaline, waste solvents and other chemical wastes, from the CTI location on Sorrento Valley Road to three residences in San Diego owned by Jvirblis located on Wrelton Drive, Corte Morea, and Bourgeois Way. The chemicals were not accompanied by a hazardous waste manifest at the time of transportation.
The waste ferric chloride and waste alkaline are federally-regulated hazardous wastes having the characteristic of corrosivity. The waste solvents are federally-regulated hazardous wastes having the characteristic of ignitability. The waste filter cake is a federally-regulated listed hazardous waste, assigned waste code F006 for wastewater treatment sludges from electroplating operations. All of these wastes are required by regulation to be transported with a uniform hazardous waste manifest. The firm admitted that Alex Jvirblish acted knowingly, that is with knowledge that the chemicals transported to the three sites were not accompanied by a hazardous waste manifest and with knowledge that the chemicals were waste that had the potential or substantial potential to be harmful to others or to the environment.
Federal search warrants were conducted at the three sites in November, 2019, and the chemicals were recovered. At one of the residences, chemicals were discovered which were too unstable to safely transport for disposal. The area was evacuated, and the chemicals were detonated on site by the Sheriff’s Department Bomb Squad.
“These kind of violations have the potential to jeopardize public health and damage the environment,” said U.S. Attorney Robert Brewer. “We will hold companies accountable when they take short cuts that put people and our environment at risk.”
San Diego FBI Special Agent in Charge Scott Brunner stated, “Today's plea was made possible by extraordinary investigative effort expended in a compressed time frame by the San Diego Environmental Crimes Task Force. The FBI is grateful for the integral support of the San Diego Fire Department, San Diego Police Department, San Diego County Department of Environmental Health (HAZMAT) and the Environmental Protection Agency, in expeditiously locating and neutralizing these dangerous chemicals."
“The law protects our communities and the environment by requiring proper storage, transportation, and disposal of hazardous waste,” said Acting Special Agent-in-Charge Scot Adair of EPA’s Criminal Investigation Division in California. “This case demonstrates that EPA and its law enforcement partners are committed to holding knowing violators of those requirements accountable for their actions."
Sentencing is set before U.S. District Judge John A. Houston on March 16, 2020, at 11:00 am.
Green Stormwater Rules Adopted in New Jersey
The New Jersey DEP formally adopted groundbreaking amendments to the state’s stormwater management rules to better protect water quality by reducing polluted runoff through implementation of green infrastructure technologies, which also helps to make New Jersey more resilient to storm and flood impacts from climate change, Commissioner Catherine R. McCabe announced.
emphasize how engineering with nature and focusing on green infrastructure strategies can be more effective at managing polluted runoff and reducing flooding when compared to older stormwater collection systems and approaches.
“Nature is one of our best allies in reducing flooding risks and managing stormwater runoff that pollutes waterways,” Commissioner McCabe said. “These amendments, resulting from extensive discussions with stakeholders and experts, mark a milestone in how New Jersey manages and regulates stormwater. The DEP is working with stakeholders on additional stormwater management rule changes to even further advance Governor Murphy’s commitment to protecting the environment and making the state more resilient to the impacts of climate change.”
Stormwater runoff is a major source of water pollution throughout New Jersey and across the nation. Every day, runoff from storms carries fertilizers, pesticides, automotive fluids and other pollutants into waterways, degrading ecosystems and impairing lakes, streams and rivers. Poorly controlled stormwater also exacerbates dangerous flooding conditions, and the increase in projected rainfall and extreme whether due to climate change creates added risk for harm to people and property from stormwater runoff.
A cornerstone of these new stormwater rules is the requirement for permit applicants to use green infrastructure
, rather than more traditional engineered structures, to reduce stormwater runoff and achieve water quality goals.
Green infrastructure includes a broad range of technologies – which can be implemented by homeowners, businesses, municipalities and counties – including rain gardens, bioretention basins, vegetated swales and green roofs. In addition, green infrastructure technologies have become much more practical at managing runoff from paved surfaces and roofs.
Green infrastructure more naturally manages stormwater, allowing better infiltration of above-ground stormwater into the ground water deeper beneath our feet. This infiltration process is simple: It uses vegetation and soil to naturally filter out pollutants. Green infrastructure can also include ways to store some stormwater runoff for later beneficial reuse, such as irrigation.
In addition to protecting and better managing stormwater, these approaches beautify communities and help in the fight against climate change by creating carbon-sequestering green space. Creating these green spaces also mitigates the “heat-island effect” caused by construction and paving, which can raise average temperatures in urban areas more than in less developed areas.
The amendments, which also redefine the types of surfaces subject to the rules and changes to better support water quality-protection efforts in urban communities with combined sewer systems, will take effect in one year, allowing time for a smooth transition to the new requirements.
The DEP’s work on the amendments has spanned years of research and cooperation with other state agencies and stakeholders. Key to success has been a series of stakeholder meetings comprised of engineers, scientists, state and municipal officials, environmental groups and business leaders who offered creative suggestions on making protections even better.
“I am proud of the collaborative work accomplished by the DEP and all our stakeholders in working toward these important amendments,” Assistant Commissioner for Water Resources Management Michele Putnam said. “As the most densely populated state, New Jersey must remain proactive and open to better ways to manage stormwater.”
The one-year effective date for implementation will help in the transition of management of reviews for projects at the state and local levels and provide flexibility to major developments that are currently in the design and planning process. It also provides time for municipalities to develop accompanying local ordinances and for training of design engineers and municipal review staff.
Treating Wastewater with Ozone Could Convert Pharmaceuticals into Toxic Compounds
With water scarcity intensifying, wastewater treatment and reuse are gaining popularity. But some methods for killing microbes in wastewater create disinfection byproducts (DBPs) that could be harmful to human health. Now researchers have found that ozone treatment and subsequent chlorination can convert trace amounts of some pharmaceuticals in wastewater into DBPs called halonitromethanes. They reported their results
in Environmental Science & Technology
The combination of ozone and chlorine kills most bacteria and viruses in wastewater. Compared with chlorine treatment alone, ozone also reduces the formation of many DBPs. Recently, however, scientists have discovered that ozone can increase the formation of potentially toxic halonitromethanes, such as chloropicrin, in chlorine-treated wastewater. Jiaming Lily Shi and Daniel McCurry wanted to determine which molecules in the wastewater were being converted to chloropricin and how.
To find out, the researchers collected wastewater samples from three treatment plants in Southern California. The team discovered that ozone treatment produced nitromethane, which could have been formed from some nitrogen-containing drugs in the wastewater, including stimulants such as ephedrine and methamphetamine and certain antidepressants. Then, chlorination transformed the nitromethane into chloropricin. The pharmaceuticals, which enter wastewater through sewage, are not removed completely by conventional wastewater treatment. Future work should address how effectively processes that occur after ozone treatment can remove the nitromethane intermediate, the researchers say.
Uni-Kool Fined for Violating Federal Chemical Safety Standards
EPA announced a settlement with The Uni-Kool Partners (Uni-Kool) corporation to resolve alleged violations of the federal Clean Air Act. The violations pertain to chemical accident prevention requirements at Uni-Kool’s produce storage and distribution facility in Yuma.Uni-Kool will pay a $26,250 civil penalty and spend at least $98,438 to further improve environmental, health and safety conditions at the facility.
Uni-Kool’s industrial refrigeration system uses large quantities of anhydrous ammonia, a toxic chemical highly corrosive to skin, eyes and lungs. Thousands of facilities nationwide make, use and store extremely hazardous substances, including anhydrous ammonia. Catastrophic accidents at these facilities—historically about 150 each year—result in fatalities and serious injuries, evacuations, and other harm to human health and the environment. The Uni-Kool case falls under EPA’s National Compliance Initiative, a program to reduce risks of accidental releases at anhydrous ammonia refrigeration facilities.
“Ensuring facilities lower the risk of releases of hazardous substances is paramount in our mission to protect human health,” said John Busterud, EPA’s Regional Administrator for the country’s Pacific Southwest. “This settlement encourages Uni-Kool to invest in making its Yuma facility safer for the local community.”
A 2018 EPA inspection of the 42-acre facility found Uni-Kool violated Clean Air Act regulations by failing to safely manage anhydrous ammonia. The company also failed to timely and accurately submit chemical inventory information regarding the ammonia at the facility to the State of Arizona and local emergency response agencies, in violation of the Emergency Planning and Community Right-to-Know Act.
In addition, the inspection found several deficiencies in the facility’s compliance with requirements relating to hazard assessment, pipe and instrument labeling, training, operation, safety information reporting, and mechanical integrity.
Uni-Kool has addressed the identified violations. As part of the settlement, the company agreed to complete a supplemental environmental project valued at $98,438 to enhance safety equipment and procedures at the Yuma facility. The project includes installing a new alarm system with sensors to detect ammonia leaks that will automatically shut down the ammonia system, trigger ventilation fans and notify all within the facility of an emergency through strobe lights and horns.
For more information on The Clean Air Act’s Risk Management Plan Program and EPA’s work related to hazardous chemicals, please visit these websites:
Air Pollution is One of the World's Most Dangerous Health Risks
Researchers have calculated that the effects of air pollution shorten the lives of people around the world by an average of almost three years.
Polluted air is a public health hazard that cannot be evaded. It is widely known that long-term exposure to air pollution enhances the risks of cardiovascular and respiratory diseases. Scientists from the Max Planck Institute for Chemistry and the University Medical Center Mainz now calculated in a new study
that the global, public loss of life expectancy caused by air pollution is higher than many other risk factors such as smoking, infectious diseases or violence.
Air pollution caused 8.8 million premature deaths worldwide in 2015. This corresponds to an average reduction in life expectancy per capita of 2.9 years. In comparison, tobacco smoking reduces the life expectancy by an average of 2.2 years (7.2 million deaths), HIV / AIDS by 0.7 years (1 million deaths), parasitic and vector-borne diseases such as malaria - by 0.6 years (600,000 deaths). “Air pollution exceeds malaria as a cause of premature death by a factor of 19; it exceeds violence by a factor of 17 and HIV / AIDS by a factor of 9. Given the huge impact on public health and the global population, one could say that our results indicate an air pollution pandemic,” said Jos Lelieveld, director at Max Planck Institute for Chemistry and first author of the study.
This study is the first to examine the global impact of air pollution on human health compared to other risk factors worldwide. “Our comparison of different global risk factors shows that ambient air pollution is a leading cause of premature mortality and loss of life expectancy, in particular through cardiovascular diseases”, says Thomas Münzel, director of the Cardiology Center at the University Medical Center in Mainz and co-author of the paper.
The scientists examined the connection between exposure to pollutants and the occurrence of diseases. In order to calculate the worldwide exposure to pollutants, which primarily include fine particles and ozone, the researchers used an atmospheric chemical mode. They then combined the exposure data with the Global Exposure - Mortality Model that derives from many epidemiological cohort studies. Using these tools and data, scientists investigated the effects of different pollution sources, distinguishing between natural (wildfires, aeolian dust) and anthropogenic emissions, including fossil fuel use. Based on their results they could estimate the disease-specific excess mortality and loss of life expectancy in all countries world-wide.
The study results show that the mortality caused by ambient air pollution is highest in East Asia (35%) and South Asia (32%), followed by Africa (11%), Europe (9%) and North- and South America (6%). Lowest mortality rates are found in Australia (1.5%) associated with the strictest air quality standards of all countries. “We understand more and more that fine particles primarily favor vascular damage and thus diseases such as heart attack, stroke, cardiac arrhythmia and heart failure. It is of outmost importance that air pollution is adopted as a cardiovascular risk factor and that it is distinctly mentioned in the ESC/AHA guidelines of prevention, acute and coronary syndromes and heart failure,” continued Münzel.
According to the findings of the study, almost two thirds of the deaths caused by air pollution, namely around 5.5 million a year are avoidable, and the majority of polluted air comes from the use of fossil fuels. The researchers estimate that the average life expectancy world-wide would increase by more than a year if the emissions from the use of fossil fuels were eliminated.
The team from the University Medical Center Mainz and Max Planck Institute for Chemistry published a similar paper last year focusing on the consequences of air pollution in Europe. According to the earlier study, nearly 800,000 Europeans die prematurely every year due to illnesses caused by air pollution. Polluted air shortens the lifespan of Europeans by more than two years.
Senators Propose Phase Down Use of HFCs
Senators John Kennedy (R-La.) and Tom Carper (D-Del.) have introduced an amendment to the American Energy Innovation Act that would direct the EPA to implement a phase down of the production and consumption of hydrofluorocarbons over the next 15 years. These chemicals, known as HFCs are potent greenhouse gases used primarily as coolants in refrigerators and air conditioning systems.
Identical to the senators’ American Innovation and Manufacturing (AIM) Act
, which is currently supported by a bipartisan group of 32 Senators – 16 Republicans and 16 Democrats – this amendment would benefit U.S. industries that directly use or produce fluorocarbons and employ more than 593,000 Americans. This amendment would:
- Save American consumers $3.7 billion over 15 years;
- Increase U.S. manufacturing output by almost $39 billion over seven years; and,
- Result in the creation of 150,000 more American jobs.
“If we want to keep American competitive in global industry, we need to continue investing in alternatives to HFCs. The amendment that dozens of my colleagues have cosponsored would save billions of dollars and create thousands of jobs—all while we protect the environment. Business and environmental groups support the American Innovation and Manufacturing Act. If we give up the chance to move this amendment forward, America is going to look up in a few years and be the odd man out of the economic success that comes from transitioning away from HFCs,” said Kennedy.
“American companies have invested billions of dollars to produce and sell the next-generation technologies to replace HFCs. Our bipartisan amendment protects and builds upon these investments, and it would result in 150,000 new American jobs and almost $39 billion in annual economic benefits. At the same time, joining the rest of the global community in reducing HFCs could help avoid up to a half degree Celsius in global warming by the end of the century. I hope our colleagues will join us in supporting this amendment that will help American businesses and workers do well while doing what’s good for our planet,” said Carper.
The AIM Act was crafted with input from the manufacturing industry and environmental groups to give businesses a clear timeline for transitioning to new innovations in refrigerants. The ultimate goal is to ensure a smooth phasedown that doesn’t disrupt jobs and leave the U.S. behind in an emerging global market. The global market is moving away from the use of HFC refrigerants, given that the Kigali Amendment to the Montreal Protocol requires their phase-out.
Sens. Kennedy and Carper are joined by Sens. Bill Cassidy (R-La.), Chris Coons (D-Del.), Susan Collins (R-Maine), Sheldon Whitehouse (D-R.I.), Todd Young (R-Ind.), Dianne Feinstein (D-Calif.), Jerry Moran (R-Kan.), Brian Schatz (D-Hawaii), Lindsey Graham (R-S.C.), Cory Booker (D-N.J.), Joni Ernst (R-Iowa), Jeff Merkley (D-Ore.), Tom Cotton (R-Ark.), Chris Van Hollen (D-Md.), Chuck Grassley (R-Iowa), Edward Markey (D-Mass.), John Boozman (R-Ark.), Doug Jones (D-Ala.), Roy Blunt (R-Mo.), Richard Blumenthal (D-Conn.), David Perdue (R-Ga.), Martin Heinrich (D-N.M.), Cindy Hyde-Smith (R-Miss.), Ben Cardin (D-Md.), Richard Burr (R-N.C.), Chris Murphy (D-Conn.) and Angus King (I-Maine) in cosponsoring the amendment.
Three Companies Fined for Selling Emissions Control Defeat Devices
EPA announced it has reached settlements with three Inland Northwest sellers and manufacturers of aftermarket automotive parts specializing in heavy duty diesel pickup trucks -- Diesel Power Products, Alligator Diesel Performance, and Deviant Race Parts -- to resolve alleged violations of the Clean Air Act associated with the manufacture and sale of aftermarket products that defeat the emissions control systems of heavy-duty diesel engines.
Heavy-duty diesel pickup engines emit large amounts of nitrogen oxides and particulate matter, both of which contribute to serious public health problems in the United States. These problems include premature mortality, aggravation of respiratory and cardiovascular disease, aggravation of existing asthma, acute respiratory symptoms, chronic bronchitis, and decreased lung function. Numerous studies also link diesel exhaust to increased incidence of lung cancer.
Conservative EPA estimates indicate that the installation of the defeat devices from a single year of product sales by these three companies resulted in an estimated 49 million pounds more air pollution than would have otherwise been emitted. The parts and components manufactured and sold by the companies were designed and marketed for use on makes and models of heavy-duty diesel trucks and engines manufactured by entities such as Cummins Inc., FCA US LLC, General Motors Company, and Ford Motor Company.
As part of the settlement, the companies have agreed to stop the manufacture and sale of all products the government alleges violate the CAA. The companies also paid civil penalties totaling $180,800. The penalty for each company is reduced due to the company’s limited financial ability to pay a higher penalty and stay in business.
“These companies manufactured and sold tens of thousands of aftermarket defeat devices, and as a result, tens of thousands of heavy-duty trucks now operate without the filters, catalysts and other emissions controls that help keep our air clean,” said Chris Hladick, Regional Administrator for EPA’s Region 10 office in Seattle. “These settlements will prevent future violations by requiring the companies to ensure that their products do not adversely affect emissions.”
“The EPA will not tolerate these violations of law intended to protect people’s health,” said Ed Kowalski, Director of EPA Region 10’s Enforcement and Compliance Assurance Division. “We will continue to prosecute those responsible for manufacturing, selling and installing these illegal products.”
Vehicle and engine manufacturers employ certain hardware devices -- such as exhaust gas recirculation, diesel particulate filters, and selective catalytic reduction -- as emission control systems to manage and treat exhaust to reduce levels of particulate matter, non-methane hydrocarbons, oxides of nitrogen, and carbon monoxide released into the air and thus to meet emission standards intended to protect public health. These hardware systems are operated and monitored by software systems.
Under the Clean Air Act it is unlawful “for any person to manufacture or sell, or offer to sell, or install, any part or component intended for use with, or as part of, any motor vehicle or motor vehicle engine, where a principal effect of the part or component is to bypass, defeat, or render inoperative any device or element of design installed on or in a motor vehicle or motor vehicle engine in compliance with regulations”… “and where the person knows or should know that such part or component is being offered for sale or installed for such use or put to such use.”
Power Products Unlimited, Inc., d.b.a. Diesel Power Products -- Spokane Valley, Washington
The EPA alleged that from January 1, 2017, through December 31, 2017, DPP sold at least 5,663 aftermarket products that defeat the emissions control systems of heavy-duty diesel engines in violation of the CAA. EPA conservatively estimates that a year’s worth DPP’s sales of exhaust after-treatment removal pipes alone will result in more than eight million pounds of excess air pollution over the anticipated, remaining life of the engines/vehicles. DPP has paid a civil penalty of $50,800. To read the Consent Agreement and Final Order go to: Diesel Power Products
Alligator Diesel Performance, LLC -- Hayden, Idaho
The EPA alleged that from January 1, 2016 through May 17, 2018, Alligator sold at least 31,543 aftermarket products that defeat the emissions control systems of heavy-duty diesel engines in violation of the CAA. EPA conservatively estimates that a year’s worth of Alligator’s sales of products that allowed the customer to reprogram the on-board diagnostic systems in such a way that it allowed for the removal of factory-installed emission control systems will result in more than 11 million pounds of excess air pollution over the anticipated remaining life of the engines/vehicles. Alligator paid a civil penalty of $90,000. To read the Consent Agreement and Final Order go to: Alligator
Diesel Race Parts, LLC, d.b.a. Deviant Race Parts -- Hayden, Idaho
The EPA alleged that from January 1, 2016, through May 17, 2018 Deviant manufactured and sold at least 34,915 aftermarket products that defeat the emissions control systems of heavy-duty diesel engines in violation of the CAA. EPA conservatively estimates that a year’s worth of Deviant’s sales of the products that allowed customers to remove the factory-installed exhaust gas recirculation systems will result in more than 30 million pounds of excess air pollution over the anticipated, remaining life of the engines/vehicles. Deviant has paid a civil penalty of $40,000. Deviant and Alligator, though two separate companies, are owned by the same individuals and operated at the same location. To read the Consent Agreement and Final Order go to: Deviant
Two Companies Cited for SPCC Violations
Two Massachusetts companies have agreed to come into compliance with federal regulations meant to prevent oil pollution under settlement with the EPA. The companies have both created oil spill prevention plans, helping ensure that the environment in the communities where they operate is better protected from damaging oil spills.
Under to the agreements with EPA, the companies— Lawrence Lynch Corp. of Falmouth and Fed Corp. of Dedham—will each pay $3,000 penalties. The companies also agreed to quickly correct violations of the Oil Pollution Prevention regulations under the federal Clean Water Act. These companies have oil storage capacity in quantities large enough that they are required by the federal regulations to put in place Spill Prevention, Control and Countermeasure plans to prevent spills and to minimize damage from oil spills.
"Due to the harm oil spills can cause to public health and the environment, every effort must be made to prevent oil spills and to clean them up promptly once they occur," said EPA New England Regional Administrator Dennis Deziel. "Companies that store oil have a responsibility to follow laws that are meant to protect the public and the environment."
Federal oil spill prevention, control, and countermeasure rules provide requirements for businesses that store oil and prevent oil discharges that can affect nearby water resources.
The cases include the following:
- Lawrence Lynch Corp. agreed to pay a $3,000 penalty and address violations of the Oil Pollution Prevention regulations at its asphalt and paving manufacturing facility. The company agreed to submit an amended spill prevention plan that addresses deficiencies identified in a September 2019 inspection by EPA. The plan will include a schedule that includes constructing any necessary containment, such as asphalt cement tanks.
- Fed Corp. agreed to pay a $3,000 penalty and correct violations of the Oil Pollution Prevention regulations by preparing a spill prevention plan that it then submitted to EPA in August 2019. Fed Corp. is a general contractor with a focus on underground utility installation, site preparation, and roadway construction for public agencies and municipalities in Massachusetts.
Former Oakland Electroplating Shop Sued to Force Cleanup
California’s Department of Toxic Substances Control has filed suit
against the former owners and operators of a closed Oakland electroplating business and former landowners to require them to clean up toxic chemicals and pay more than $800,000 in penalties and unrecovered costs.
In April 2017, DTSC ordered Lisa Marie Rossi and Gerald F. Rossi, who operated the E-D Coat Inc. plating business, to remove hazardous liquids in deteriorating tanks, containers, and sumps, and to take steps to prevent the contamination of on-site and off-site soil and groundwater. DTSC also hired a contractor to remove and dispose of chemicals that posed the greatest risk, including dangerous cyanide waste from three sumps on the property.
Because the defendants failed to comply with the 2017 cleanup order, which was amended in 2019, DTSC has filed a complaint in U.S. District Court to compel the rest of the cleanup work and force the defendants to pay DTSC’s response costs and penalties for failing to comply.
The 2017 cleanup order stemmed from a multiagency investigation that uncovered deteriorating conditions at the E-D Coat site, which operated from 1966 to 2012. A U-Haul business currently operates on part of the property, and an apartment building and homes border portions of the site.
In December 2017, the Alameda County District Attorney filed a felony complaint charging Lisa Marie Rossi with a variety of hazardous waste violations related to the site. Rossi pleaded to a felony for unlawfully storing hazardous waste, agreed to comply with DTSC’s cleanup order and was placed on probation. She violated her probation because she did not comply with the cleanup order; sentencing is set for May 22, 2020.
In addition to Lisa Marie Rossi and Gerald F. Rossi in their various capacities, the complaint filed by DTSC also named as defendants E-D Coat Inc. and Patricia S. Rossi and Lee Doslak Florance as trustees of two Rossi Family Trusts.
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