RESPONDENT FAILED TO DETERMINE HAZARDOUS NATURE OF WASTE AND THEREFORE, ALSO VIOLATED MANIFEST AND CERTAIN STORAGE REQUIREMENTS. DURING INSPECTIONS OF 5/31/83 AND 9/22/84, RESPONDENT AL- LEGED THAT THE OIL SOLVENT DETERGENT WASTE PRODUCED FROM THE MACHINERY CLEANING PROCESS AT THE FACILITY WAS NOT A HAZARDOUS WASTE. THEREAFTER, REPRESENTATIVES OF EQB RE- CEIVED ANALYSIS RESULTS WHICH INDICATE THAT THIS WASTE IS A HAZARDOUS WASTE (VIOLATION OF RULE 702.B OF RCHNSW). AT TIME OF 8/22/85 INSPECTION, THE HAZ WASTE CONTAINER STORAGE AREA AT THE FACILITY CONTAINED 18 OR MORE 55-GALLON DRUMS CONTAINING HAZ WASTE, 10 OF WHICH WERE NOT MARKED WITH THE DATE STORAGE PERIODS BEGAN (VIOLATION OF RULE 704D.1.B.5 OF RCHNSW); RESPONDENT HAD BEEN TRANSPORTING OR OFFERING FOR TRANSPORT OFF-SITE, AN UNDETERMINED AMOUNT OF HAZ WASTE WITHOUT PREPARING AN ACCOMPANYING MANIFEST (VIOLATION OF RULE 703 A. OF RCHNSW); RESPONDENT HAD NOT SUBMITTED A WRIT- TEN OPERATING PLAN TO THE BOARD (IN VIOLATION OF RULE 704 D.2 OF RCHNSW); RESPONDENT HAD STORED HAZARDOUS WASTE FOR A PERIOD > 90 DAYS W/OUT FIRST COMPLYING W/ PERMIT RQRMTS OF SUBPART B OF 40 CFR PART 270 (IN VIOLATION OF RCRA/3005).