9/7/05 - COMPLAINT FILED.
COUNT I: AT THE TIME OF THE MARCH 17, 2004, INSPECTION, RESPONDENT HAD NOT MADE A HAZARDOUS WASTE DETERMINATION ON SOME OF THE 52 CONTAINERS ACCUMULATED IN THE BACKYARD AREA - IN VIOLATION OF RCRA 3002.
COUNT 2: RESPONDENT VIOLATED SECTION 3010 OF RCRA BY HAVING GENERATED HAZARDOUS WASTE WITHOUT HAVING FILED A NOTIFICATION WTH EPA OR FDEP OF ITS HAZARDOUS WASTE ACTIVITY AND RCRA 3002 BY STORING HAZARDOUS WASTE WITHOUT HAVING RECEIVED AN EPA ID NUMBER.
COUNT 3: RESPONDENT VIOLATED SECTION 3005 OF RCRA BY OPERATING A HAZARDOUS WASTE STORAGE FACILITY WITHOUT INTERIM STATUS OR A PERMIT.
COUNT 4: RESPONDENT VIOLATED SECTION 3005 OF RCRA BY OPERATING A HAZARDOUS WASTE STORAGE FACILITY WITHOT INTERIM STATUS OR A PERMIT.