THE VIOLATIONS THAT ARE THE SUBJECT OF THIS ACTION WERE DISCLOSED BY AUBURN TO EPA BY LETTERS DATED FEBRUARY 15, 2001, FEBRUARY 28, 2001, MAY 31, 2001, JUNE 1, 2001 AND JUNE 7, 2001. VIOLATIONS DISCLOSED WERE: 1. INADEQUATE SWPPP PLAN 2. FAILURE TO LABEL OR COVER K061 SATELLITE ACCUMULATION DRUMS. 3. FAILURE TO DOCUMENT LACK OF RECEIPT OF HAZARDOUS WASTE MANIFESTS. 4. FAILURE TO REPORT 20 CHEMICALS ON EPCRA TIER II SUBMISSIONS. 5. IMPROPER IDENTIFICATION OF APPROPRIATE MANUFACTURING ACTIVITY ON TRI REPORTS. 6. FAILED TO ENSURE DULY AUTHORIZED REPRESENTATIVE SIGNED APPLICATIONS AND REPORTS.