ON AUGUST 30, 1983, MDNR INSPECTED RESPONDENT'S FACILITY AND DETERMINED THAT RESPONDENT HAD RECEIVED EMISSION CON- TROL DUST FROM THE PRODUCTION OF STEEL IN ELECTRIC FUR- NACES AFTER NOVEMBER 20, 1980. UNDER 40 CFR 261.32, EMIS- SION CONTROL DUST FROM PRODUCTION OF STEEL IN ELECTRIC FURNACES IS A LISTED HAZARDOUS WASTE (K061). ON DECEMBER 3, 1984, MDNR, AS AN AUTHORIZED REPRESENTATIVE OF U.S. EPA, CONDUCTED A RCRA COMPLIANCE INSPECTION OF RESPONDENT'S FACILITY. THE SUBSEQUENT DECEMBER 3, 1984, INSPECTION REVEALED THAT THE STORAGE OF K061 WAS DONE WITHOUT COMPLYING WITH THE 40 CFR 265 REQUIREMENTS. AS A RESULT OF THE AUGUST 30, 1983 AND DECEMBER 3, 1984, INSPECTIONS, IT HAS BEEN DETERMINED THAT THE RESPONDENT VIOLATED THE FOLLOWING REQUIREMENTS OF PART 265: A) THE RESPONDENT HAS FAILED TO DEVELOP AN APPROVED WASTE ANALYSIS PLAN PURSUANT TO 40 CFR 265.13; B) THE RESPONDENT HAS FAILED TO DEVELOP AND MAINTAIN AN APPROVED INSPECTION SCHEDULE, PURSUANT TO 40 CFR 265.15; C) THE RESPONDENT HAS FAILED TO ESTABLISH AND MAINTAIN AN APPROVED EMPLOYEE TRAINING PROGRAM AND RECORDS OF PER- SONNEL AND TRAINING PURSUANT TO 40 CFR 265.16. D) THE RESPONDENT FAILED TO ESTABLISH EMERGENCY EQUIPMENT TESTING AND MAINTENANCE PROCEDURES PURSUANT TO 40 CFR 265.33; E) THE RESPONDENT FAILED TO SECURE ARR