EPA determined that Respondent at, the time of the July 2016 Inspection, or at times prior thereto, had failed to: (1) make hazardous wastes determinations for certain waste-streams found at the Norwich facility; (2) keep a complete copy of each hazardous waste manifest for at least three years; and (3) meet the conditions necessary to accumulate hazardous waste without having obtained a permit or qualifying for interim status. Seeking resolution through payment of a penalty.