APC INSTALLED A SOLVENT RECOVERY SYSTEM SOMETIME AFTER THE LAST WDNR INSPECTION (1992). THIS SYSTEM ACCUMULATES SPENT SOLVENT FROM THREE LARGE PARTS WASHERS INTO A RCRA HAZARDOUS WASTE TANK. THE TANK IS USED TO STORE THE SPENT SOLVENTS PRIOR TO THEM BEING CONVEYED TO THE DISTILLATION UNIT. AT THE TIME OF THE INSPECTION, APC WAS NOT MANAGING THESE MATERIALS AS HAZARDOUS WASTE FROM THE POINT OF GENERATION UP UNTIL THEY HAD ENTERED THE STILL. THIS SUGGEST THAT APC WAS VIOLATING WISCONSIN REQUIREMENTS ASSOC- IATED WITH NOT HAVING PREFORMED A HAZARDOUS WASTE DETER- MINATION AND ALL TANK REQUIREMENTS FOR LQG'S FOUND AT NR 615.05(4)(A)(3) AND THE TECHNICAL TANK STANDARDS FOUND WITHIN NR 645. APC COULD ALSO BE IN VIOLATION OF SUBPART BB & CC REQUIREMENTS FOR ANCILLARY EQUIPMENT TO THE TANK AND THE TANK ITSELF. ECAB HAS MADE AN INITIAL DETERMINATION THAT THE DISTILLATION UNIT WOULD NOT BE SUBJECT TO AIR EMISSION REQUIREMENTS, NOR THE EQUIPMENT THAT IS ANCILLARY TO THE DISTILLATION UNIT.