EPA ACTION ARISES OUT OF A 1990 ORDER ISSUED BY CONNECTICUT DEP TO A PREDECESSOR OF DANNY CORP WHICH REQURED ACTIONS TO ADDRESS RELEASES OF PCBs IN OILY WASTEWATER FROM 500 FLATBUSH AVE., HARTFORD, CT (THE SITE ). IN RESPONSE TO THE ORDER, DANNY CORP'S PREDECESSOR CONSTRUCTED A PCB GROUNDWATER RECOVERY SYSTEM, WHICH CONSISTED OF INTERCEPTOR TRENCHES FROM WHICH OILY WSTEWATER WAS PUMPED INTO STORAGE TANKS IN A BERMED SECONDARY CONTAINMENT AREA; THEN OIL FROM THESE TANKS WHICH CONTAINED PCBs AT GREATER THAN 50PPM, WAS TRANSFERRED INTO DRUMS WHICH WERE SENT OFF-SITE FOR DISPOSAL. THE OPERATION OF THIS SYSTEM GAVE RISE TO FIVE VIOLATIONS OF LABELING AND RECORDKEEPING REQUIREMENTS FOR PCB WSTE IN STORAGE FOR GREATER THAN 30 DAYS. THESE VIOLATIONS WERE DOCUMENTED IN INSPECTIONS CONDUCTED BY CONNECTICUT DEP IN 2005.