On September 30, 2011, Region 1 issued an Administrative Complaint and Compliance Order to Roberts Chemical Company, Inc. (Respondent) alleging violations of Section 3002 of RCRA and the Rhode Island Rules and Regulations for Hazardous Waste Management. At the time of the violations alleged in the Complaint, Respondent operated a chemical distribution, manufacturing and storage facility located in Pawtucket, Rhode Island (RI Facility). The Complaint cites Respondent for violating numerous federal and state hazardous waste management requirements. In January 2011, Respondent closed the RI Facility and moved its business to a facility located in Attleboro, Massachusetts (MA Facility). EPA is ordering Respondent to comply with all applicable requirements of RCRA and the Massachusetts Hazardous Waste Management Act, and regulations promulgated thereunder, at the MA Facility.