THIS REFERRAL INCORPORATES TWO STATUTES INVOLVING VULCRAFT; RCRA AND CAA. THE VIOLATIONS ARE: RCRA: CONDUCTING ILLEGAL TREATMENT OF A HAZARDOUS WASTE WITHOUT A PERMIT FOR EVAPORATION OF PAINT WASTES ON THE PROCESSING FLOOR; FAILURE TO MAINTAIN A SATELLITE ACCUMULATION POINT WITHIN THE CONTROL OF THE OPERATOR AND NEAR THE POINT OF WASTE GENERATION; AND FAILURE TO DEVELOP AN ADEQUATE TRAINING PROGRAM FOR WORKERS WHO MANAGE HAZARDOUS WASTE. CAA: FAILURE TO KEEP PAINT DIP TANKS IN THE JOIST MANUFACTURING PLANT COVERED WHEN THEY ARE NOT IN USE; AND EXCEEDING THE MAJOR SOURCE PSD THRESHOLD IN 1990, BUT DID NOT REPORT THE EMISSION INCREASE TO THE STATE OR APPLY FOR PSD REVIEW AT THAT TIME. THE PROPOSED PENALTIES ARE: RCRA - $183,047 AND CAA - $1,355,000.