Wisconsin DOJ Announces $1.65 Million Agreement with Container Life Cycle Management LLC Resolving Air and Hazardous Waste Violations

Oct 18 2022

MADISON, Wis. – The Wisconsin Department of Justice (DOJ) announced today a proposed settlement of $1.65 million between Container Life Cycle Management LLC (CLCM), the United States, and the State of Wisconsin to resolve CLCM’s violations of air and hazardous waste laws at its container reconditioning facilities in Milwaukee County. In addition to the proposed monetary settlement of $1.65 million, CLCM will be required to comply with a container management plan and install control and monitoring technology for air emissions at its Oak Creek and St. Francis facilities.


“This resolution sends a clear message that our hazardous waste laws must be followed,” said Attorney General Kaul. “It will also help prevent unlawful air pollution at CLCM’s facilities in Wisconsin in the future.”


CLCM currently operates container reconditioning facilities in Oak Creek and St. Francis. Until June 2020, CLCM also operated a container reconditing facility in Milwaukee. Wisconsin and the United States jointly investigated CLCM’s compliance with environmental laws at its facilities. Wisconsin alleges that CLCM violated air laws at its Oak Creek and St. Francis facilities and hazardous waste laws at all three of its facilities.


“We take all violations of this nature very seriously, and it is important to hold polluters accountable, when necessary,” said Department of Natural Resources Secretary Preston Cole. “Protecting the health and safety of the public is a key part of our mission as an agency. Our Attorney General shares our goals and he has prioritized public health in this case.”


The proposed consent decree requires CLCM to pay $1.65 million. The proposed consent decree also requires CLCM to:

  • Comply with a container management plan at its facilities. That plan requires proper identification and storage of hazardous waste as well as reporting to the Department of Natural Resources (DNR) and U.S. Environmental Protection Agency (EPA).
  • Install additional capture and monitoring technology on the drum washing lines at the St. Francis facility. CLCM must then complete air testing to verify that the St. Francis facility is controlling volatile organic compound and hazardous air pollutant emissions as required by law.
  • Install monitors to record when the drum reclamation furnace at the Oak Creek facility is operating and comply with emission limits for the furnace. CLCM must also complete air testing to verify that the furnace is complying with those emission limits.
  • Submit permit applications to DNR to incorporate requirements in the proposed consent decree into its air permits for the St. Francis and Oak Creek facilities.


Wisconsin DOJ Public Protection Unit Assistant Attorneys General Emily M. Ertel and Sarah C. Geers represented Wisconsin. Wisconsin DOJ worked closely with DNR, EPA, and U.S. DOJ staff to obtain this result.


Wisconsin DOJ referred the proposed settlement to the Joint Committee on Finance of the Wisconsin Legislature for review on September 22, 2022. A copy of the memorandum submitting this proposed settlement to the Joint Committee on Finance for Review is available here.