The violations alleged in the Complaint can be categorized into four distinct types: (1) the failure to make a hazardous waste and LDR determination as required by 40 C.F.R. Section 262.11 and 268.34; (2) the unpermitted storage of hazardous waste in a waste pile in violation of RCRA Section 3005(a) and 40 C.F.R. Section 270.1, and the failure to comply with all applicable permitting requirements for hazardous waste pile under 40 C.F.R. Part 162 and the Virginia regulations which incorporate the federal rules by reference; (3) the failure to comply with certain provisions of the Land Disposal Restriction ( LDR ) regulations at 40 C.F.R. Part 268; and (4) six shipments of unmanifested hazardous waste to an unpermitted facility in violation of 40 C.F.R. Sections 262.12 and .20(a), and 9 VAC 20-60