Respondent was inspected in September 2009 and February 2010. The complaint cites three counts: 1) Failure to make a hazardous waste determination for hazardous waste rags and fluorescent light bulbs, 2) Failure to have or document a hazardous waste training program, and 3) Failure to obtain a permit (or complying with requirements necessary to be exempt from permitting). EPA is requiring immediate compliance with RCRA, either obtain a hazardous waste storage permit or meet the conditions to be exempt from such permit. Penalty payment and injunctive relief.