1. Respondent was storing the following hazardous waste in satellite accumulation containers that were not labeled with the words hazardous waste or other words to identify their contents as required by COMAR 26.13.03.05E(3)(b), and the applicable permit exemption condition set forth at COMAR 26.13.03 .05.E( 1 )(f)(ii):
2. Respondent was storing the following hazardous waste in a 90-Day container that was not marked with a start accumulation date as required by COMAR
3. On March 21, 2017, Respondent violated the requirements of COMAR 26.13.05.090 by failing to hold hazardous waste in containers that are always kept closed during storage, except when it is necessary to add or remove waste.
4. On March 21, 2017, Respondent also violated the requirements of COMAR 26.13.05.021 by failing to provide sufficient aisle space, at a minimum of 2 feet in width, to allow for inspections of the Facility and compliance with COMAR 26.13.05.03F.
5. From February 26, 2016 to June 12, 2018, Respondent violated the requirements of COMAR 26.13.05.04C(3), ( 4) and (5), by failing to have a contingency plan that included arrangements by local response organizations to coordinate emergency services, contact information for the emergency coordinators, or a list of emergency equipment and their locations.
6. During the following time periods, March 21, 2014 through March 31, 2015, and April 1, 2016 through March 21, 2017, for a total of646 days, Respondent violated the requirements of COMAR 26