The respondent failed to Submit Notification: The facility did not submit the required notification to the EPA prior to managing hazardous secondary materials, as mandated by 40 C.F.R. ? 261.4(a)(23)(ii)(c), Improperly Labeled Containers:, and accumulated Universal Waste lamps for longer than one year from the date of generation, contrary to the requirements of 40 C.F.R. ? 273.15(a).