AN INSPECTION OF THE BUR FACILITY CONDUCTED ON SEPTEMBER 16-18, 2003 BY DULY AUTHORIZED EPA PERSONNEL REVEALED THE FAILURE OF BUR TO OPERATE ITS FACILITY IN COMPLIANCE WITH APPLICABLE HAZARDOUS WASTE TREATMENT, STORAGE AND DISPOSAL STANDARDS, SPECIFICALLY THE ORGANIC AIR EMISSIONS REGULATIONS. TWO INSPECTIONS OF THE UOR FACILITY, A PERMITTED HAZARDOUS WASTE MANAGEMENT FACILITY, IN JUNE AND JULY 2003 AND SEPTEMBER 2003 BY DULY AUTHORIZED REPRESENTATIVES OF THE CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION REVEALED THE FAILURE OF UOR TO OPERATE ITS FACILITY IN COMPLIANCE WITH ITS PERMIT AND WITH APPLICABLE HAZARDOUS WASTE GENERATOR STANDARDS, INCLUDING VIOLATIONS OF PERMIT REQUIREMENT GOVERNING HAZARDOUS WASTE ANALYSIS AND VERIFICATION TESTING, NON-ACCEPTANCE OF CERTAIN UNPERMITTED WASTES, AND REGULATORY PERMITTING AND CONTAINER MANAGEMENT REQUIREMENTS. THE STATE HAS REFERRED THE VIOLATIONS OF UOR FACILITY TO EPA.
THE REGION RECOMMENDS THAT A CIVIL PENALTY IN THE AMOUNT OF $480,879 BE IMPOSED, AND THAT INJUNCTIVE RELIEF BE SOUGHT REQUIRING (i) REQUIRING BUR AND UOR TO COMPLY WITH ALL APPLICABLE RCRA GENERATOR AND HAZARDOUS WASTE STANDARDS; (ii) REQUIRING BUR TO DEMONSTRATE THE REMOVAL EFFICIENCY OF ITS CLOSED-VENT SYSTEM AND CONTROL DEVICE, (iii) REQUIRING BUR TO PREPARE AN ANALYSIS OF WHETHER OR NOT TANKS AND EQUIPMENT MAY BE SUBJECT TO THE REQUIREMENTS FOR LIGHT-LIQUID SERVICE, (iv) REQUIRING BUR AND UOR TO CALCULATE A DESIGN EXHAUST VENT STREAM ORGANIC COMPOUND CON