The RCRA Program inspected the water treatment operation at the Site and notified the OSCs that there was evidence of spills and releases from drums, tanks and electroplating liquids. Based on a determination of a threat of a release of hazardous substances into the environment, EPA issued a Field Notice of Federal Intent on February 28, 2008. Respondent commenced a removal action, and that work was expanded and made part of the administrative consent order referenced here.