Date: Wed, 1 Mar 2006 09:18:25 -0500
Reply-To: List Moderator <esf**At_Symbol_Here**UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: List Moderator <esf**At_Symbol_Here**UVM.EDU>
Subject: Yale University Faces $30,000 RCRA Fine for Failing to Provide
Updated Financial Guarantee Information
Comments: To: SAFETY ,
lcee-l**At_Symbol_Here**, lab-xl**At_Symbol_Here**

Yale University Faces Fine for Failing to Provide Updated Financial  
Guarantee Information
Release date:02/27/2006

Contact Information: David Deegan, (617) 918-1017

(Boston, Mass. - Feb. 27, 2006) – Yale University is facing a fine of  
nearly $30,000 for failing to meet financial assurance requirements  
of federal and state hazardous waste laws.

The EPA complaint, which could result in a fine of $28,375, states  
that Yale violated the financial assurance requirements of the  
Resource Conservation and Recovery Act (RCRA) by failing to submit  
updated financial assurance information to the Connecticut Department  
of Environmental Protection (CT DEP) for the years 2003 and 2004.

The action is part of a new federal initiative to ensure that  
companies and institutions that handle hazardous waste have the funds  
available to properly clean up areas where the hazardous wastes have  
been treated, stored or disposed of when they stop the hazardous  
waste activity.

Yale University operates a greater-than-90-day storage facility at  
its Wright Nuclear Structure Laboratory (WNSL), where it stores  
containers of hazardous waste mixed with radioactive waste. As a  
facility that stores hazardous waste for greater than 90 days, Yale  
was required to comply with the requirements applicable to treatment,  
storage and disposal facilities, including the requirement to  
maintain financial assurance for closure of the WNSL storage area.

EPA began the nationwide effort to enforce financial requirements of  
RCRA after the agency’s Inspector General issued a report indicating  
that many companies might not be in compliance with laws regarding  
financial assurance. EPA's New England regional office conducted a  
review of the files of the Connecticut environmental agency to  
determine if facilities in that state were in compliance with the  
law. After reviewing the CT DEP’s files, compliance problems were  
identified for many facilities, including Yale.

As a participant in EPA’s College and University Audit Initiative in  
2002, Yale disclosed, among other violations, that it was not  
maintaining financial assurance for the WNSL. Later that year, Yale  
submitted to CT DEP documents demonstrating that it met its financial  
assurance obligations. However, EPA’s file review found that Yale  
failed to provide annual updates to its financial assurance  
documentation for fiscal years 2003 and 2004.

For more information: 


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