THIS IS A RCRA SECTION 3008(A) CIVIL ENFORCEMENT ACTION BASED ON THE COMPANY'S ILLEGAL OPERATION OF HAZARDOUS WASTE MANAGEMENT UNITS SINCE 1980. THE COMPANY FAILED TO PROPERLY NOTIFY EPA OF THESE UNITS, NEVER FILED PART A OF A RCRA PERMIT APPLICATION, AND NEVER COMPLIED WITH INTERIM STATUS REQUIREMENTS. THE REFERRAL ALSO RECOMMENDS THAT THE COMPLAINT INCLUDE A COUNT FOR ILLEGAL DISPOSAL OF HAZARDOUS WASTE AT THE FACILITY'S HEAT EXCHANGE BUNDLE CLEANING PAD.