Lifestyle Footwear, Inc., in carrying out its manufacturing operations and application of basic and industrial chemicals, chemical intermediates, and solvents, maintenance services, and mechanic services, and in the course of conducting normal maintenance operations, has been generating solid waste and hazardous waste , as the terms are defined in 40 C.F.R.Section 261.2 and in 40 C.F.R. Section 261.3, repectively. The facility failed to characterize and properly manage the RCRA hazardous waste generated in various manufacturing areas. Therefore, under the authority of Section 3008(a)(3) of RCRA, 42 U.S.C. Section 6928(a)(3), and the RCRA Civil Penalty Policy, and based on the seriousness of the violations to comply with applicable RCRA requirements, EPA proposed the assessment of a civil penalty in the total amount of 140,328.