THIS COMPLAINT & CONSENT AGREEMENT/FINAL ORDER IS ISSUED PER RCRA SECTION 3008(A)(1) TO SPECIFIC PLATING CO. INC. THE VIOLATION INVOLVES STORAGE OF HAZARDOUS WASTE WITHOUT A PERMIT; STORAGE OF HAZARDOUS WASTE FOR LONGER THAN 90 DAYS; FAILURE TO LABEL CONTAINERS WITH THE ACCUMULATION START DATE AND WITH THE WORDS HAZARDOUS WASTE ; FAILURE TO HAVE A PERSONNEL TRAINING PLAN; AND FAILURE TO MAINTAIN A FACILITY-SPECIFIC CONTINGENCY PLAN. THE COMPLAINT SEEKS A PENALTY OF $45,595.