'Complaint filed 9/27/2002, proposing a penalty of $322,291. Count 1 - Respondent stored thirteen (13) drums of hazardous waste without a permit or interim status from 9/23/98 through 10/1/99. Count 2 - Respondent failed to conduct a detailed chemical and physical analysis on the thirteen drums of hazardous waste. Count 3 - Respondent failed to conduct facility inspections as required. Count 4 - Respondent failed to develop and implement a complete personnel training program. Count 5 - Respondent failed to develop a contigency plan. Count 6 - Respondent failed to keep a written operating record at the facility. Count 7 - Respondent failed to develop a written closure as required. Count 8 - Respondent failed to develop a cost estimate for closure. Count 9 - Reespondent failed to establish financial assurance for possible closure of the facility. Count 10 - Respondent failed to conduct inspections of the containers as required. Count 11 - Respondent failed to prepare a hazardous waste manifest