BASED ON INSPECTIONS AND STACK TESTS CONDUCTED SINCE DECEMBER 1994, EPA DOCUMENTED PARTICULATE AND VISIBLE EMISSION VIOLATIONS AT THE FACILITY'S SLUDGE INCINERATORS. DOCUMENT REVIEWS ALSO CONFIRMED SIGNIFICANT AND CONTINUING VIOLATIONS OF OPERATING PERMIT AND PLAN APPROVAL CONDITIONS WHICH GOVERN OPERATION OF THE FACILITY'S INCINERATORS AND POLLUTION CONTROL DEVICES, AS WELL AS NUMEROUS MONITORING AND RECORDKEEPING VIOLATIONS. THESE VIOLATIONS REPRESENT SIGNIFICANT ENVIRONMENTAL NON- COMPLIANCE WITH THE NEW SOURCE PERFORMANCE STANDARDS OF PERFORMANCE FOR PENNSYLVANIA STATE IMPLEMENTATION PLAN. EPA ISSUED NOVS TO DELCORA FOR THESE VIOLATIONS IN APRIL AND SEPTEMBER, 1995 AND THE REGION IS NOW SEEKING A CIVIL PENALTY OF $400,000 AND INJUNCTIVE RELIEF, INCLUDING CAPITAL IMPROVEMENTS AND IMPROVED OPERATIONS AND MAINTENANCE PRACTICES AT THE FACILITY.