OPERATION OF TSD FACILITY W/O PERMIT AND NON-COMPLIANCE WITH INTERIM STATUS STANDARD. GENERATOR ACCUMULATED IN EXCESS OF 90 DAYS. UNUSAL OR SIGNIFICANT LEGAL ISSUES: QUESTIONS ON HOW TO REACH FACILITIES THAT DO NOT HAVE INTERIM STATUS. REMEDIES/RELIEF SOUGHT: CLOSURE & $14,250 CIVIL PENALTY. SETTLEMENT FOR $4,500 CIVIL PENALTY.