Claims 1. Failure to Notify of Changes to Hazardous Waste Management Activity
19. The allegations in paragraphs 1-19 are re-alleged and incorporated herein by reference.
20. As a generator of hazardous waste during the years 2016 through 2019, Respondent was required by LAC 33:V.1105, the portion of the authorized Louisiana RCRA program implementing section 3010(a) of RCRA, 42 U.S.C. ? 6930(a), to notify the Office of Environmental Services within seven days if any of the information submitted in its initial application for an EPA ID number changes.
21. During the years 2016 through 2019, Respondent?s most recent notification of hazardous waste activity (NOR) indicated that Respondent generated less than 100 kilograms per month of hazardous waste.
22. During 2016, 2017, 2018, and 2019, Respondent failed to notify the appropriate administrative authority that its hazardous waste activity submitted in its last NOR had changed to reflect the generation activity described in paragraph 18, violating the requirements of Louisiana?s authorized RCRA program at LAC 33:V.1105.B.
Claims 2. Failure to Comply with Waste Storage Requirements
23. The allegations in paragraphs 1-26 are realleged and incorporated herein by reference.
24. During the period of 2016 to 2019, Respondent accumulated waste generated at the facility prior to transport, constituting short term ?storage? as defined in 33 LAC:V.109 [40 C.F.R. ? 260.10].
25. During the period of 2016 to 2019, Respondent, as