N.H. All of the violations stem from Clean Water Act requirements. Among other violations, EPA cited the company for failing to apply for a stormwater discharge permit, for discharging stormwater without a permit and for failing to file semi-annual monitoring reports related to pretreatment of industrial wastewater. The facility's wastewater is discharged to a municipal wastewater treatment facility. Suncook Leather also was cited for failing to maintain its 1974 spill prevention plan, which is required for the operation of the company's 15,000-gallon fuel tank which is situated five feet from the river.
Federal law requires that the spill prevention plan be reviewed and evaluated every three years.
The stormwater discharge violations are especially disturbing considering that the company stores substantial quantities of hides, hide scraps and wastewater treatment sludge outdoors, where they are exposed to stormwater that eventually discharges into the river. EPA inspectors discovered the violations during a series of inspections in 1996 and 1997.