REGION 3 ALLEGES IN THE CAFO THAT AFS VIOLATED RCRA §3005 AND THE AUTHORIZED VHWMR BY STORING HAZARDOUS WASTE WITHOUT A PERMIT AND WITHOUT COMPLYING WITH THE CONDITIONS TO QUALIFY FOR EXEMPTION FROM RCRA PERMIT REQUIREMENTS INCLUDING AMONG OTHER THINGS; MARKING CONTAINERS WITH ACCUMULATION START DATES AND THE WORDS ÂHAZARDOUS WASTE. IN ADDITION, AFS ALLEGEDLY FAILED TO MEET CERTAIN OTHER CONDITIONS FOR EXEMPTION FROM THE PERMIT REQUIREMENTS UNDER THE VHWMR AND VIOLATED THE PROHIBITION ON STORING LAND DISPOSAL RESTRICTED HAZARDOUS WASTES AS WELL AS THE HAZARDOUS WASTE STORAGE FACILITY STANDARDS IN THE VHWMR BY, AMONG OTHER THINGS: 1) FAILING TO KEEP CONTAINERS CLOSED; 2) FAILING TO PERFORM AND/OR RECORD TANK INSPECTIONS; 3) FAILING TO MINIMIZE THE POSSIBILITY OF A RELEASE OF A HAZARDOUS WASTE CONSTITUENT; 4) FAILING TO MAINTAIN UNOBSTRUCTED AISLE SPACE IN A HAZARDOUS WASTE STORAGE AREA; AND 5) FAILING TO TIMELY FILE TWO BIENNIAL REPORTS.