FROM AT LEAST JANUARY 1, 2008 UNTIL JUNE 30, 2010, RESPONDENT FAILED TO QUALIFY FOR THE LESS THAN 90 DAY GENERATOR ACCUMULATION EXEMPTION OF 9 VAC 20-60-262(A), WHICH INCORPORATES BY REFERENCE 40 C.F.R. SECTION 262.34(A) WITH EXCEPTIONS NOT RELEVANT HEREIN, BY FAILING TO SATISFY THE CONDITIONS FOR THE EXEMPTION AS SET FORTH IN 9 VAC 20-60-262(A).
2. RESPONDENT STORED HAZARDOUS WASTE AT THE FACILITY WITHOUT A PERMIT, INTERIM STATUS OR VALID EXEMPTION, IN VIOLATION OF 9 VAC-20-60-270(A), WHICH INCORPORATES BY REFERENCE 40 C.F.R. SECTION 3005(A) OF RCRA, 42 U.S.C. SECTION 6925(A).
3. RESPONDENT FAILED TO MAKE A HAZARDOUS WASTE DETERMINATION FOR THE SOLID WASTE CONTENTS OF TANK NOS. 58, 71 AND 72 AND THE FLUORESCENT BULBS AT THE FACILITY, IN VIOLATION OF 9 VAC 20-60-262 AND 40 C.F.R. SECTION 262.11.
4. RESPONDENT FAILED TO PROVIDE INITIAL AND ANNUAL REVIEW TRAINING IN CALENDAR YEARS 2007 AND 2008 TO THE FACILITY'S PLANT MANAGER AND TO SEVERAL EMERGENCY COORDINATORS IN 2008.
5. THE FACILITY'S FAILURE TO PROVIDE FADCILITY PERSONNEL WHOSE POSITIONS REQUIRED KNOWLEDGE OF HAZARDOUS WASTE MANAGEMENT AT THE FACILITY WITH INITIAL AND ANNUAL REVIEW HAZARDOUS WASTE MANAGEMENT TRAINING DESCRIBED IN PARAGRAPH 32 ABOVE IN 2007 AND 2008 WAS A VIOLATION OF 9 VAC 20-60-262(A) AND 40 C.F.R. SECTION 264.16(A)-(C).
6. FROM AT LEAST DECEMBER 8, 2007 UNTIL JUNE 30, 2010, RESPONDENT FAILED TO MAINTAIN DOCUMENTATION OF THE JOB TITLES AND JOB DESCRIPTIONS FOR POSITIONS AT THE FACILITY R