ON MARCH 27, 2001, THE UNITED STATES ENVIRONMENTAL PROTECT- ION AGENCY, REGION 5 (U.S. EPA), FILED AN ADMINISTRATIVE COMPLAINT AGAINST JOYNER'S DIE CASTING & PLATING COMPANY (JOYNER'S), 7801 XYLON AVENUE NORTH, BROOKLYN PARK, MINNESO- TA. THE COMPLAINT ALLEGED VIOLATIONS OF CERTAIN REQUIREMENT S OF THE RESOURE CONSERVATION AND RECOVERY ACT (RCRA), 42 U.S.C. 6901 ET SEQ., AS AMENDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984 (HSWA), PUB. L. 98-616. THE VIOLA- TIONS ALLEGED IN THE COMPLAINT CONSISTED OF THE FOLLOWING: COUNT I(MN 7045.0214.1/40 CFR 262.11): JOYNER'S FAILED TO DETERMINE WHETHER THE CONTENTS OF A DRUM OF MATERIAL LOCATED AT THE SILVER PLATING CONSTITUTED HAZARDOUS WASTE. COUNT II(40 CFR 270.1(C) AND MN 7045.0292,8,B,2/40 CFR 262 34(C)(1)(II): JOYNER'S FAILED TO OBTAIN A PERMIT OR INTERIM STATUS FOR THE STORAGE OF HAZARDOUS WASTE BY FAILING TO COM- PLY WITH 40 C.F.R. 262.34, 265.16, 265 SUBPART I. SPECI- FICALLY, (1) JOYNERS FAILED TO MARK CONTAINERS OF HAZARDOUS WASTE COPPER CYANIDE AND LACQUER STRIP RINSE WASTE WHICH WERE STORED IN SATELLITE ACCUMULATION IN THE WASTE TREATMENT ROOM, AND ANOTHER CONTAINER OF HAZARDOUS WASTE WHICH WERE STORED IN SATELLITE ACCUMULATION IN THE WASTE TREATMENT ROOM AND ANOTHER CONTAINER OF HAZARDOUS WASTE IN THE PAINT ROOM, WITH THE WORDS HAZARDOUS WASTE OR WITH OTHER WORDS THAT IDENTIFIED THE CONTENTS OF THE CONTAINERS, IN VIOLATION OF 40 C.F.R. 262.34(C)(1)(II) AND MIN