1. From at least January I, 2011 until May 3, 2016, Respondent did not meet the requirements for a permit exemption under COMAR 26.13.03.0SE and therefore violated COMAR 26.13.07.0 I A and Section 3005(a) of RCRA, 42 U.S.C. 6925(a), by operating a hazardous waste storage facility (i.e., the Facility) without a permit or interim status.
2. On May 3, 2016, Respondent violated COMAR 26.13.03.02 by failing to perform hazardous waste determinations on solid waste generated at the Facility.
3. On May 3, 2016, Respondent violated COMAR 26.13.03.06 A(l) by failing to keep a copy of each manifest signed in accordance with COMAR 26.13 .03 .04A{l) for three years or until Respondent received a signed copy from the designated facility which received the waste.
4. From March 2, 2012 through and including May 20, 2013 and from March 2, 2016 through and including May 27, 2016, Respondent violated COMAR 26.13.03.068(1 )(b)(ii) and (c)(ii) by failing to submit biennial reports due March 1, 2012 and March 1, 2016 by the due date for such biennial reports.
5. From May 3, 2011 through and including May 3, 2016, Respondent violated COMAR 26.13.05.02G( I )(a) and (c) by failing to provide hazardous waste management training that teaches the employees to perform their duties in a way that ensures compliance with the MdHWMR, and at a minimum is designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency