RESPONDENT OPERATED AS A TREATMENT, STORAGE, DISPOSAL FACILITY WITHOUT INTERIM STATUS OR RCRA PERMIT, FAILED TO COMPLY WITH MANIFEST AND LDR NOTIFICATION REQUIREMENTS AND FAILED TO COMPLY WITH APPLICABLE BIANNUAL REPORT REQUIREMENTS. THESE VIOLATIONS ARE BEING RESOLVED IN A SETTLEMENT AGREEMENT THAT WILL CONSIST OF A $53,078 PROPOSED PENALTY AND REQUIRED COMPLIANCE ACTIONS.