FAILURE TO KEEP PERCHLOROETHYLENE RECORDS AND FILE REPORTS W/ EPA. OPERATING A MAJOR SOURCE WITHOUT A TITLE V PERMIT. **CCDS SUMMARY*** RESPONDENT FAILED TO SUBMIT A TIMELY APPLICATION FOR TITLE V PERMIT; FAILED TO FILE INITIAL NOTIFICATION AND TO OPERATE DRY CLEANING EQUIPMENT WITHOUT A TITLE V PERMIT; FAILED TO FILE COMPLIANCE STATUS NOTIFICATION W/EPA; FAILED TO PERFORM REQUIRED RECORDKEEPING; AND FAILED TO PROPERLY PERFORM RE- QUIRED MONITORING, IN VIOLATION OF THE CAA. RESPONDENT ALSO STORED SPENT PERCHLOROETHYLENE CONTAMINATED WASTEWATER AT ITS FACILITY FOR GREATER THAN 90 DAYS WITHOUT HAVING OB- TAINED A RCRA PERMIT, INTERIM STATUS OR AN EXTENSION TO THE 90-DAY STORAGE PERIOD; FAILED TO CONDUCT DAILY INSPECTIONS OF THE TANK SYSTEMS WHERE IT WAS STORING PERCHLOROETHYLENE CONTAMINATED WASTES; FAILED TO KEEP RECORDS DOCUMENTING IN- SPECTIONS OF THE TANKS SYSTEMS; FAILED TO DEVELOP A CONTIN- GENCY PLAN TO ADDRESS RELEASES OF HAZARDOUS WASTE FROM THE FACILITY; FAILED TO TRAIN ITS EMPLOYEES IN THE HANDLING OF HAZARDOUS WASTES AT ITS FACILITY; FAILED TO DETERMINE THE VOLATILE ORGANIC COMPOUND CONTENT OF THE WASTES STORED IN TANKS AT ITS FACILITY, IN VIOLATION OF THE RCRA. *** THE SETTLEMENT WILL REQUIRE FAIRFIELD TO UNDERTAKE A NUMBER OF REMEDIAL ACTIONS, INCLUDING: CESSATION OF USE OF PERCHLO- ROETHYLENE AS A DRY CLEANING AGENT;