ON MAY 13, 1996 EPA INSPECTORS FOUND APPROXIMATELY 200 CONTAINERS ON THE GROUND AT THE HAVERHILL DPW FACILITY, APPROXIMATELY 10 OF WHICH HELD HAZARDOUS WASTE. THE FACILITY WAS STORING THESE WITHOUT A RCRA PERMIT, THEREBY VIOLATING RCRA'S PERMIT REQUIREMENT AS WELL AS MANY OF THE RCRA REQUIREMENTS THAT FLOW FROM THE PERMIT REQUIREMENT. ALSO, THE FACILITY, WHICH STORED A LOT OF OIL, DID NOT HAVE A CWA SPCC PLAN.