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UOR Response to EPA Enforcement Action

   USEPA has issued a press release announcing the settlement United has reached with them to resolve issues with RCRA inspections at our TSD facilities in Meriden and Bridgeport in 2003.  The Meriden facility was cited for improper "hazardous waste analysis and verification testing, acceptance of un-permitted wastes, and regulatory permitting and container management requirements". 

  All of the alleged violations were resolved immediately after the inspections in 2003 and subsequent inspections have shown the facility to be in compliance with the facility's permit and the RCRA regulations.  The allegation that the facility accepted waste for which it was not permitted is incorrect.  UOR demonstrated through documentation that it had the authority to accept the subject waste streams.  There was no rebuttal and no part of the civil penalty is attributed to the allegation.  The "hazardous waste analysis and verification testing" allegation revolved around a single waste stream and it was the sampling method that was incorrect, not the analysis.  "Container management requirements" refers to the absence of a label on one drum of hazardous waste.

   Bridgeport United Recycling is and has been in compliance with the EPA regulations concerning organic air emissions from tanks of hazardous waste.  The company performed a successful emission test in 2006 that demonstrated that the system, as designed and operated at the time of inspection, met the performance standard in the regulations.  Despite the fact that the facility's emissions were and are very low, much lower than those of other facilities subject to the regulation, United and USEPA could not come to agreement on certain operating conditions and recordkeeping practices.  United decided to settle the action rather than continue and escalate the dispute.

   It's also useful to point out that both facilities have been issued RCRA permits since the inspections.  This would not have occurred if there were ongoing issues.

Please contact Bill Morris at (203) 238-6745 with any questions.

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