The action was issued to address: (1) failure to make hazardous waste determinations (2) failure to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste and (3) failure to obtain either a hazardous waste permit or interim status, or, in the alternative, comply with conditions for the safe short-term accumulation of hazardous waste without a permit. The facility had achieved compliance prior to the EPA action and transferred BMPs to other corporate locations.