SEE ALSO PREVIOUS MATTER NUMBER 04-97-0189. (ARCHIVED) COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO MARK DRUMS. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.40(A) (1). COUNT II RESPONDENT FAILED TO REMOVE AND DISPOSE OF THE DRUMS WITHIN ONE YEAR OF THEIR PLACEMENT IN STORAGE. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.65(A) AND SECTION 15(1) OF TSCA. COUNT III RESPONDENT DID NOT DATE THE DRUMS WHEN THEY WERE PLACED IN STORAGE AT THE IRF. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.65(C)(8) AND SECTION SECTION 15(1) OF TSCA. COUNT IV RESPONDENT STORED DRUMS AT THE IRF THAT DID NOT MEET THE CRITERIA SET FORTH IN 40 C.F.R. SECTION 761.65(B). IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.65(B) AND SECTION 15(1) OF TSCA. COUNT V