1305TP_Stericycle_NoticeofSettlement_FID1990153_20250313

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March 13, 2025
North Carolina Department of Environmental Quality
Division of Waste Management - Solid Waste Section
1646 Mail Service Center
Raleigh, NC 27699-1646
RE: Stericycle, Inc. - Notice of Settlement
Solid Waste Management Facility Permit to Operate No.1305TP-TP
To Whom It May Concern:
Stericycle, Inc. ("Stericycle") holds a Solid Waste Management Facility Operating Permit No.1305TP-TP from the North
Carolina Department of Environmental Quality Division of Waste Management Solid Waste Section.
This letter serves as a notice to the North Carolina Department of Environmental Quality pursuant to N.C. Gen. Stat.
§ 130A-295.3(d).
Stericycle entered into a Stipulation and Order of Settlement (the "Settlement Agreement") with the United States of
America, acting on behalf of the United States Environmental Protection Agency, for alleged violations —occurring
between May 5, 2014, and April 6, 2020—of the Resource Conservation and Recovery Act ("RCRA"), 42 U.S.C. § 6901
et seq.; and the regulations promulgated pursuant thereto, found at 40 C.F.R. Parts 260 through 279. The Settlement
Agreement pertains to a business that Stericycle sold on April 6, 2020, and since that date, Stericycle has largely ceased
managing hazardous waste in the United States. The Settlement Agreement requires that "Stericycle shall pay to the
United States the sum of $9,500,000 as a civil penalty, together with interest accruing from the Date of Filing at the rate
specified in 28 U.S.C. § 1961 as of the Date of Filing." The government filed to obtain court approval of the Settlement
Agreement on January 17, 2025, and the court approved the final Settlement Agreement on February 13, 2025.
If you have any questions, please do not hesitate to contact me, at [e-mail]; or Stericycle's outside
counsel, Elise Paeffgen of Alston & Bird LLP, at [e-mail].
Thank you.
Sincerely,
Andrew Marks
VP & Assistant General Counsel - Regulatory
Stericycle, Inc.
Enclosure: Stipulation and Order of Settlement

Case 1:25-cv-00498-JPC Document 8 Filed 02/13/25 Page 1 of 11
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
STERICYCLE, INC.,
Plaintiff,
Defendant.
25 Civ. 498
STIPULATION AND ORDER OF
SETTLEMENT
1. WHEREAS, plaintiff the United States of America ("United States"), on behalf
of the United States Environmental Protection Agency ("EPA"), filed a Complaint (the
"Complaint") against Stericycle, Inc. ("Stericycle"), alleging that between May 5, 2014, and
April 6, 2020, Stericycle violated the Resource Conservation and Recovery Act ("RCRA"), 42
U.S.C. § 6901 et seq.; and the regulations promulgated pursuant thereto, found at 40 C.F.R.
Parts 260 through 279.
2. WHEREAS, the Complaint seeks an award of civil penalties against Stericycle
for violations occurring between May 5, 2014, and April 6, 2020;
3. WHEREAS, on April 6, 2020, Stericycle sold its Stericycle Environmental
Solutions business and Stericycle represents that, since that date, it has largely ceased managing
hazardous waste in the United States; and
4. WHEREAS, the United States and Stericycle (collectively, the "Parties")
recognize, and the Court by entering this Stipulation and Order finds, that this Stipulation and
Order has been negotiated by the Parties in good faith and will avoid litigation among the
Parties; that this Stipulation and Order is a fair and reasonable settlement of the claims asserted
by the United States, as specifically set forth in the Complaint; and that this Stipulation and
Order is fair, reasonable, and in the public interest;
NOW, THEREFORE, with the consent of the Parties, it is hereby ORDERED,
ADJUDGED, and DECREED as follows:
I. JURISDICTION AND VENUE
5. This Court has jurisdiction over the subject matter of the Complaint pursuant to
42 U.S.C. § 6928(a), and 28 U.S.C. §§ 1331, 1345, and 1355, and over the Parties. Venue lies
in this District, pursuant to 28 U.S.C. §§ 1391(b) and (c) and 1395(a), because Stericycle
conducts business in this District, and a number of the violations allegedly occurred in this
District. For purposes of this Stipulation and Order, or any action or proceeding to enforce this
Stipulation and Order, Stericycle consents to the Court's jurisdiction over this Stipulation and
Order and any such action and over Stericycle and consents to venue in this judicial district.

Case 1:25-cv-00498-JPC Document 8 Filed 02/13/25 Page 2 of 11
6. For purposes of this Stipulation and Order, Stericycle agrees that the Complaint
states a claim upon which relief may be granted pursuant to RCRA, 42 U.S.C. § 6901 et seq.
II. APPLICABILITY
7. The obligations of this Stipulation and Order apply to and are binding upon the
United States and upon Stericycle and any of its successors, assigns, or other entities or persons
otherwise bound by law.
8. Stericycle shall provide a copy of this Stipulation and Order to all officers,
employees, and agents whose duties might reasonably include compliance with any provision of
this Stipulation and Order.
9. In any action to enforce this Stipulation and Order, Stericycle shall not raise as a
defense the failure of any of its officers, directors, employees, agents, or contractors to take any
actions necessary to comply with the provisions of this Stipulation and Order.
III. DEFINITIONS
10. Terms used in this Stipulation and Order that are defined in RCRA or in
regulations promulgated pursuant to RCRA, have the meanings assigned to them in RCRA or
such regulations, unless otherwise provided in this Stipulation and Order. Whenever the terms
set forth below are used in this Stipulation and Order, the following definitions apply:
a. "Complaint" shall mean the complaint filed by the United States in this
action.
b. "Date of Filing" shall mean the date this Stipulation and Order is filed
with the Clerk of the Court for the United States District Court for the Southern District
of New York.
C. "Day" shall mean a calendar day unless expressly stated to be a business
day. In computing any period of time under this Stipulation and Order, where the last day
would fall on a Saturday, Sunday, or federal holiday, the period shall run until the close
of business of the next business day.
d. "Document" shall be defined in accordance with Local Civil Rule 26.3 of
the Local Rules of the United States District Court for the Southern District of New York.
e. "Effective Date" shall have the definition provided in Section IX.
f. "EPA" shall mean the United States Environmental Protection Agency
and any of its successor departments or agencies.
g. "Paragraph" shall mean a portion of this Stipulation and Order identified
by an Arabic numeral.
h. "Parties" shall mean the United States and Stericycle.
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Case 1:25-cv-00498-JPC Document 8 Filed 02/13/25 Page 3 of 11
i. "Plaintiff' shall mean the United States on behalf of EPA.
j. "RCRA" shall mean the Resource Conservation and Recovery Act of
1976, 42 U.S.C. § 6901 et seq.
k. "Section" shall mean, except when citing a provision of RCRA or other
statute or regulation, a portion of this Stipulation and Order identified by a Roman
numeral.
1. "Stericycle" shall mean defendant Stericycle, Inc.
in. "United States" shall mean the United States of America, acting on behalf
of EPA.
IV. ADMISSIONS
11. Stericycle admits, acknowledges, and accepts responsibility for the following
facts:
a. On numerous occasions between May 5, 2014 and April 6, 2020,
Stericycle, by and through its transporters, subsidiaries, and subcontractors for
transportation services, was the transporter of RCRA-regulated hazardous waste
shipments for RCRA-regulated hazardous waste generators, and failed to deliver part or
all of the hazardous waste shipment described on the shipment's manifest (as that term is
defined in 42 U.S.C. § 6903(12)) to the designated facility on the manifest.
b. On numerous occasions between May 5, 2014 and April 6, 2020,
Stericycle (or one of its subsidiaries or subcontractors) served as a transporter of RCRA-
regulated hazardous waste shipments to one of Stericycle's RCRA-regulated Treatment,
Storage, and Disposal facilities ("TSDF"), and failed to ensure that a manifest
accompanied all hazardous waste shipments.
C. On numerous occasions between May 5, 2014 and April 6, 2020,
Stericycle failed to timely provide RCRA-regulated hazardous waste generators with
final signed copies of their hazardous waste shipment manifests within 30 days after the
shipments were delivered to Stericycle TSDFs.
d. On numerous occasions between June 2018 and April 2020, Stericycle
failed to timely submit hazardous waste manifests to EPA's national system for
electronically tracking hazardous waste shipments —known as the e-Manifest system —
within 30 days after the date of delivery of the hazardous waste shipment to Stericycle
TSDFs.
e. On numerous occasions between May 5, 2014 and April 6, 2020,
Stericycle failed to consult with a generator prior to changing the destination of
hazardous waste as designated on a hazardous waste manifest.

Case 1:25-cv-00498-JPC Document 8 Filed 02/13/25 Page 4 of 11
f. On numerous occasions between May 5, 2014 and April 6, 2020,
Stericycle stored hazardous waste at its hazardous waste transfer facilities (as that term is
defined in 40 C.F.R. § 260.10) for longer than the ten-day limits.
V. CIVIL PENALTY
12. Within 60 Days after the Effective Date, Stericycle shall pay to the United States
the sum of $9,500,000 as a civil penalty, together with interest accruing from the Date of Filing
at the rate specified in 28 U.S.C. § 1961 as of the Date of Filing.
13. Stericycle shall pay the civil penalty due to the United States by FedWire
Electronic Funds Transfer ("EFT"), in accordance with instructions provided to Stericycle by the
United States Attorney's Office for the Southern District of New York after the Effective Date.
The payment instructions will include a Consolidated Debt Collection System ("CDCS")
number, which Stericycle shall use to identify all payments required to be made in accordance
with this Stipulation and Order.
14. At the time of payment, Stericycle shall send notice and proof of payment: (i) to
EPA's Cincinnati Finance Center via email at cinwd [e-mail]; (ii) to DOJ via
email or regular mail in accordance with Section VIII; and (iii) to EPA in accordance with
Section VIII. Such notice shall state that the payment is for the civil penalty owed pursuant to
the Stipulation and Order in United States v. Stericycle, Inc., and shall reference the civil action
number, CDCS Number and DOJ case number 90-7-1-12831. "Proof of payment" means
confirmation of wire or automated clearinghouse transfer, and any other information required to
demonstrate that payment has been made according to these requirements, in the amount due.
15. Stericycle shall not deduct any penalties paid under this Stipulation and Order
pursuant to this Section in calculating its federal income tax.
16. If Stericycle fails to pay the civil penalty required to be paid under Paragraph 12
when due, Stericycle shall pay a stipulated penalty of $1,000 per Day for each Day that the
payment is late. Stericycle shall pay such stipulated penalty within 30 Days of receiving the
United States' written demand. Stericycle shall pay such stipulated penalty in the manner set
forth in Paragraph 13. If Stericycle fails to pay stipulated penalties according to the terms of this
Stipulation and Order, Stericycle shall be liable for interest on such stipulated penalties, as
provided for in 28 U.S.C. § 1961, accruing as of the date payment became due. Interest under
28 U.S.C. § 1961 shall accrue on any unpaid civil penalty or stipulated penalty that is due to be
paid until such payment is made. Nothing in this Paragraph shall be construed to limit the
United States from seeking any remedy otherwise provided by law for Stericycle's failure to pay
the civil penalty or any stipulated penalty due hereunder.
VI. EFFECT OF SETTLEMENT/RESERVATION OF RIGHTS
17. This Stipulation and Order resolves only: (1) the civil claims of the United States
against Stericycle for the violations alleged in the Complaint in this action through April 6,
2020; (2) any civil claims of the United States against Stericycle pursuant to RCRA Section
3008(a), 42 U.S.C. § 6928(a), that allege violations, through April 6, 2020, of 40 C.F.R.
4

Case 1:25-cv-00498-JPC Document 8 Filed 02/13/25 Page 5 of 11
§ 263.12(a); 40 C.F.R. Part 263, subpart B; 40 C.F.R. Part 264, subpart E; 40 C.F.R. Part 265,
subpart E; and 40 C.F.R. § 262.20(d), to the extent such claims arise from the August 19, 2019
Civil Investigative Demand issued by the U.S. Attorney's Office for the Southern District of
New York; and (3) civil claims against a corporate successor to Stericycle or other acquirer of
any portion of Stericycle's business, to the extent that such civil claims are premised on
vicarious successor liability for the violations described in (1) and (2) through April 6, 2020.
18. The United States reserves all legal and equitable remedies available to enforce
the provisions of this Stipulation and Order, except as expressly stated in Paragraph 17. This
Stipulation and Order shall not be construed to limit the rights of the United States to obtain
penalties or injunctive relief under RCRA or its implementing regulations, except as expressly
specified in the preceding Paragraph. The United States further reserves all legal and equitable
remedies to address any imminent and substantial endangerment to the public health or welfare
or the environment arising at, within, or posed by, Stericycle, whether related to the violations
addressed in this Stipulation and Order or otherwise.
19. In any subsequent administrative or judicial proceeding initiated by the United
States for injunctive relief, civil penalties, other appropriate relief relating to Stericycle, or
Stericycle's violations, Stericycle shall not assert, and may not maintain, any defense or claim
based upon the principles of waiver, res judicata, collateral estoppel, issue preclusion, claim
preclusion, claim -splitting, or other defenses based upon any contention that the claims raised by
the United States in the subsequent proceeding were or should have been brought in the instant
case, except with respect to claims that have been specifically resolved pursuant to Paragraph
17.
20. Except as provided by Paragraph 17, this Stipulation and Order does not limit or
affect the rights of Stericycle or of the United States against any third parties, not party to this
Stipulation and Order, nor does it limit the rights of third parties not party to this Stipulation and
Order against Stericycle, except as otherwise provided by law.
21. This Stipulation and Order shall not be construed to create rights in, or grant any
cause of action to, any third party not party to this Stipulation and Order.
22. For avoidance of doubt, nothing in this Stipulation and Order affects any liability
of any person for violations of law occurring on or after April 6, 2020.
VII. COSTS
23. The Parties shall bear their own costs of this action, including attorneys' fees,
except that the United States shall be entitled to collect the costs (including attorneys' fees)
incurred in any action necessary to collect any portion of the civil penalty or any stipulated
penalties due but not paid by Stericycle.
VIII. NOTICES
24. Unless otherwise specified in this Stipulation and Order, whenever notifications,
submissions, or communications are required by this Stipulation and Order, they shall be made
in writing and sent by mail or email, with a preference for email, addressed as follows:
5

Case 1:25-cv-00498-JPC Document 8 Filed 02/13/25 Page 6 of 11
As to the United States: Tomoko Onozawa
Dominika Tarczynska
Assistant United States Attorneys
U.S. Attorney's Office, Southern District of New York
86 Chambers Street, 3rd Floor
New York, New York 10007
Email: [e-mail]
[e-mail]
Re: United States v. Stericycle, Inc.
DJ # 90-7-1-12831
As to the EPA: Lauren Stroyeck
Attorney -Advisor
Office of Civil Enforcement
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW
Mailcode: 2249A
Washington, DC 20460
Email: [e-mail]
As to Stericycle: Terra Reynolds
Meredith Monroe
Latham & Watkins LLP
330 N. Wabash, Suite 2800
Chicago, IL 60611
Email: [e-mail]
[e-mail]
25. Any Party may, by written notice to the other Parties, change its designated
notice recipient or notice address provided above or whether notice to that Party shall be
provided by mail or email.
26. Notices submitted pursuant to this Section shall be deemed submitted upon
mailing or transmission by email, unless otherwise provided in this Stipulation and Order or by
mutual agreement of the Parties in writing.
IX. EFFECTIVE DATE
27. The Effective Date of this Stipulation and Order shall be the date upon which this
Stipulation and Order is entered by the Court or a motion to enter the Stipulation and Order is
granted, whichever occurs first, as recorded on the Court's docket.
2

Case 1:25-cv-00498-JPC Document 8 Filed 02/13/25 Page 7 of 11
X. RETENTION OF JURISDICTION
28. The Court shall retain jurisdiction over this case until all payments required by
Section V have been made, for the purpose of resolving disputes arising under this Stipulation
and Order, or effectuating or enforcing compliance with the terms of this Stipulation and Order.
XI. MODIFICATION
29. The terms of this Stipulation and Order may be modified only by a subsequent
written agreement signed by all the Parties. Where the modification constitutes a material
change to the Stipulation and Order, it shall be effective only upon approval by the Court.
XII. SIGNATORIES/SERVICE
30. Each undersigned representative of Stericycle and the U.S. Department of
Justice certifies that he or she is fully authorized to enter into the terms and conditions of this
Stipulation and Order and to execute and legally bind the Parry he or she represents to this
document.
31. This Stipulation and Order may be signed in counterparts, and its validity shall
not be challenged on that basis. Stericycle agrees to accept service of process by mail with
respect to all matters arising under or relating to this Stipulation and Order and to waive the
formal service requirements set forth in Rules 4 and 5 of the Federal Rules of Civil Procedure
and any applicable Local Rules of this Court including, but not limited to, service of a summons.
Stericycle need not file an answer to the Complaint unless or until the Court expressly declines
to enter this Stipulation and Order. Stericycle consents to entry of this Stipulation and Order
without further notice.
XIII. INTEGRATION
32. This Stipulation and Order, including deliverables that are subsequently approved
pursuant to this Decree, constitutes the entire agreement among the Parties regarding the subject
matter of the Decree and supersedes all prior representations, agreements and understandings,
whether oral or written, concerning the subject matter of the Stipulation and Order herein.
XIV. HEADINGS
33. Headings to the Sections and Subsections of this Stipulation and Order are
provided for convenience and do not affect the meaning or interpretation of the provisions of
this Stipulation and Order.
XV. FINAL JUDGMENT
34. Upon approval and entry of this Stipulation and Order by the Court, this
Stipulation and Order shall constitute a final judgment of the Court as to the United States and
Stericycle.
VA

Case 1:25-cv-00498-JPC Document 8 Filed 02/13/25 Page 8 of 11
SO ORDERED this istnday of February , 2025.
Hon. John P. Cronan
UNITED STATES DISTRICT JUDGE

Case 1:25-cv-00498-JPC Document 8 Filed 02/13/25 Page 9 of 11
FOR THE UNITED STATES OF AMERICA:
Dated: Januar} 17. 2025
MATTHEW PODOLSKY
Chief Counsel to the Acting United States Attorney
for the Southern District of New York,
Attorney for the United States,
Acting under Authority Conferred by
28 U.S.C. § 515
By: V M & Qv2x���
D ;IM INIKA TARCVYNSKA
I IElm to] I SiZeIIe
Assistant United States Attorneys
86 Chambers Street, 3rd Floor
New York, New York 10007
E

Case 1:25-cv-00498-JPC Document 8 Filed 02/13/25 Page 10 of 11
FOR THE U.S. ENVIRONMENTAL PROTECTION AGENCY:
Dated: January 14, 2025
+CECIL RODRIGUES
Acting Assistant Administrator
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
OF COUNSEL:
Lauren Stroyeck
Attorney -Advisor
Office of Civil Enforcement
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460
10

Case 1:25-cv-00498-JPC Document 8 Filed 02/13/25
Page 11 of 11
FOR DEFENDANT STERICYCLE, INC.:
Dated: January 9, 2025
By:
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UT& "S
Oaa0E225Ae4a4aa..
Terra Reynolds
Meredith Monroe
LATHAM & WATKINS LLP
330 North Wabash Avenue
Suite 2800
Chicago, Illinois 60611
Counsel for Defendant Stericycle. Inc.
ao;aiyned by:
By: sgooaa+�aaz.dss.
Rafael Carrasco
President
On behalf of Stericycle, Inc.