BASED ON THREE INSPECTIONS OF RESPONDENT FACILITIES SINCE AUGUST 2003 AND OTHER INFORMATION DEVELOPED SINCE THEN, THE COMPLAINT ALLEGES THAT RESPONDENT VIOLATED RCRA AND CWA BY FAILING TO MAKE HAZARDOUS WASTE DETERMINATIONS; FAILING TO MINIMIZE THE POSSIBILITYOF A RELEASE OF HAZARDOUS WASTE OR HAZRDOUS WASTE CONSTITUENTSAT ONE OF THE FACILITIES; FAILING TO PROVIDE ADEQUATE HAZARDOUS WASTE WITHOUT A PERMIT. THE COMPLAINT SEEKS CIVIL PENALTIES FOR THE ALLEGED VIOLATIONS, BUT DOES NOT PROPOSE A SPECIFIC PENALTY AMOUNT. THE ACTION IS EXPECTED TO RAISE AWARENESS OF ENVIRONMENTAL REQUIREMENTS AMONG MARINAS AND IMPROVE COMPLIANCE.