RESPONDENT VIOLATED RCRA REQUIREMENTS BY INADEQUATE CONTAINER MANAGEMENT; STORAGE OF INCOMPATIBLE WASTE; FAILURE TO MINIMIZE THE POSSIBILITY OF RELEASE OF HAZARDOUS WASTE TO THE ENVIRONMENT; FAILURE TO MAKE HAZARDOUS WASTE DETERMINATIONS; FAILURE TO MAINTAIN SECONDARY CONTAINMENT; FAILURE TO PROPERLY MANAGE RECEIVED HAZARDOUS WASTE; AND IMPROPER CONTROL OF AIR EMISSIONS FROM HAZARDOUS WASTE TANKS. THE COMPLAINT PROPOSES A PENALTY OF $204,362.