Respondent failed to perform a hazardous waste determination and 2) operated as a treatment, storage or disposal facility without a RCRA permit or RCRA Interim Status as a result of Respondent?s failure to comply with satellite accumulation container requirements for closing and labeling; contingency plan requirements regarding updating the plan and describing certain actions in the plan; failure to document some hazardous waste tank inspections; and failure to contain hazardous waste.