1.AT THE TIME OF THE JUNE 12 -13, 2013 RCRA CEI, RESPONDENT DID NOT KEEP A CONTAINER HOLDING D001 HAZARDOUS WASTE PAINT CLOSED DURING STORAGE WHEN IT WAS NOT NECESSARY TO ADD OR REMOVE WASTE, AS REQUIRED BY 25 PA. CODE 262A.10, WHICH INCORPORATES BY REFERENCE 40 C.F.R 262.34(A)(1 )(I) AND THE CONTAINER USE AND MANAGEMENT REQUIREMENTS OF 40 C.F.R. 265.173(A).
2. AT THE TIME OF THE JUNE 12- 13,2013 RCRA CEI, RESPONDENT ACCUMULATED D002 HAZARDOUS WASTE CAUSTIC CLEANING SOLUTION IN A NEW TANK SYSTEM WHICH HAD BEEN INSTALLED WITHOUT FIRST OBTAINING A WRITTEN ASSESSMENT ATTESTING THAT THE SYSTEM HAS SUFFICIENT STRUCTURAL INTEGRITY AND IS ACCEPTABLE FOR THE STORING AND TREATMENT OF HAZARDOUS WASTE.
3. AT THE TIME OF THE JUNE 12 - 13, 2013 RCRA CEI, RESPONDENT ACCUMULATED D002 HAZARDOUS WASTE CAUSTIC CLEANING SOLUTION IN A TANK THAT DID NOT HAVE SECONDARY CONTAINMENT AS REQUIRED BY 40 C.F.R. 265.193.
4.ON JUNE 12- 13, 2013, RESPONDENT ACCUMULATED D002 HAZARDOUS WASTE CAUSTIC CLEANING SOLUTION IN A NEW TANK SYSTEM WITHOUT PERFORMING INSPECTIONS EACH SUCH OPERATING DAY TO ENSURE THE TANK SYSTEM WAS BEING OPERATED ACCORDING TO ITS DESIGN AS REQUIRED BY 25 PA. CODE 262A.10, WHICH INCORPORATES BY REFERENCE 40 C.F.R. 262.34(A)(1)(II), AND THE HAZARDOUS WASTE STORAGE TANK INSPECTION REQUIREMENTS OF 40 C.F.R. 265.195(A).
5.RESPONDENT FAILED TO QUALIFY FOR THE LESS THAN 90-DAY GENERATOR ACCUMULATION EXEMPTION OF 25 PA.CODE 262A.10, WHICH INCORPORATES BY REFERENCE THE REQUIREM