This is a civil administrative enforcement action instituted pursuant to Section 3008(a)(1) of the Resource Conservation and Recovery Act (?RCRA?), as amended, 42 U.S.C. ? 6928(a)(1), and the Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties and the Revocation/Termination or Suspension of Permits, as codified at 40 C.F.R. Part 22 (?Consolidated Rules?). The alleged violations are operating without a permit due to storage of hazardous waste in excess of 90 days.