On September 9, 2004, U.S. EPA issued a RCRA � 3008(a) complaint against ITW Foils, located in Mt. Pleasant, Michigan which is within the boundaries of the Chippewa Indian Tribe and thus located within Indian Country. U.S. EPA is alleging that ITW Foils was not complying with tank system requirements. Specifically, ITW Foils operates a new tank system and did not have a tank integrity assessment nor certification signed by an independent, qualified, registered engineer to the tank systems integrity. U.S. EPA also alleged that ITW Foils had not instituted a leak, monitoring and repair program to monitor air emissions from effected pieces of equipment which come in contact with hazardous waste containing more than 10% organic concentrations. And finally, U.S. EPA is alleging two acts of noncompliance with respect to container management: failure to keep containers closed, and failure to provide pertinent information. The complaint included a proposed penalty of $61,002.