RESPOUDENT FAILED TO NOTIFY EPA THAT THEY GENERATE, STORE AND DISPOSE OF HAZARDOUS WASTE, AND FAILED TO COMPLY WITH ALL APPLICABLE REQUIREMENTS OF RCRA. THE COMPANIES WILL PAY A CIVIL PENALTY OF $156,865 AND WILL COMPLY WITH ALL APPLICABLE REQUIREMENTS OF RCRA AND WILL DEVELOP PROCEDURES THAT GOVERN THE PROPER IDENTIFICATION AND SHIPMENT OF HAZARDOUS WASTE GENERATED BY THE FACILITY.