The Respondent was a large e-waste recycling processor and, until October 2010, a significant exporter of CRT glass containing TC levels of lead. Since October 2010, the facility ceased exporting CRT glass but continued to receive and process CRTs at their Vestal, NY processing facility from where crushed and whole CRT glass was shipped to their Hallstead, PA warehouse for storage. The Respondent accumulated millions of pounds of CRT glass at their Hallstead, PA facility. On January 1, 2012, the Respondent was in violation of 40 CFR 261.1(c)(8) and approximately 26 million pounds of CRT glass became a solid waste. The Hallstead site flooded twice since 2010 resulting in the release of a significant percentage of crushed lead glass from their Gaylord containers. The Super Complaint cites the facility for operating a hazardous waste storage facility without a permit. The CAFO seeks to assure that the Respondent sorts and properly disposes of all remaining glass, including 26 million pounds of hazardous waste, within specific time limits; a large penalty was not sought since this may have resulted in making it financially impossible for the owner of the company to properly sort and dispose of all stored CRT glass and leaving the site mop clean . An inspection of the Vestal, NY facility in April 2015 by EPA verified that that site has ceased operations and the site was clean with no waste or material remaining.