In 2013, the University of Connecticut (?UConn?), in response to the identification of polychlorinated biphenyls (?PCBs?) in window caulk at two residence halls at the UConn?s Storrs campus, undertook a window replacement project. In addition to PCB Bulk Product Waste, PCB Remediation Waste was generated during the project. UConn signed the manifest but did not identify the PCB Remediation Waste as PCB Remediation Waste, resulting in shipment to a facility not licensed to handle PCB Remediation Waste. The shipment was not in compliance with TSCA. 40 C.F.R. 761.50(a), 761.50(b)(3), and 761.61.
In performing the project, UConn hired as a consultant ATC Associates (?ATC?), an environmental consultant based in East Hartford, Connecticut. UConn also contracted with A&A Window Services to perform the project; A&A subcontracted with Dec-Tam for disposal services.
EPA negotiated with UConn and the parties agreed on a $28,000 penalty per the CAFO.