'COMPLAINT AND COMPLIANCE ORDER ISSUED 9/27/2001 PROPOSING A PENALTY OF $27,500. RESPONDENT FAILED TO COMPLETE A HAZARDOUS WASTE DETERMINATION ON SOLID WASTE GENERATED AT THE FACILITY. RESPONDENT DID NOT HAVE AN INTERIM STATUS OR A PERMIT. RESPONDENT FAILED TO UTILIZE PROTECTIVE MEASURES SUCH AS REQUIRING THAT THE ROLL-OFF CONTAINERS BE SEALED AND/OR UTILIZE SECONDARY CONTAINMENT WHILE COLLECTING METAL CONTAMINATED WITH USED OIL, CUTTING OILS, HAZARDOUS WASTE, OR HAZARDOUS WASTE CONSTITUENTS. RESPONDENT DID NOT HAVE A PERMIT TO TREAT HAZARDOUS WASTE AT THE FACILITY. RESPONDENT FAILED TO PREVENT UNTREATED LAND DISPOSAL RESTRICTED HAZARDOUS WASTE FROM BEING DISPOSED UPON THE LAND. RESPON- DENT DOES NOT HAVE A RCRA PERMIT OR INTERIM STATUS FOR THE STORAGE OF HAZARDOUS WASTE. RESPONDENT FAILED TO PROVIDE ANNUAL REFRESHER TRAINING TO THREE EMPLOYEES MANAGING HAZARDOUS WASTE. RESPONDENT DOES NOT HAVE A RCRA PERMIT OR INTERIM STATUS FOR THE STORAGE OF HAZARDOUS WASTE.