COMPLAINT AND COMPLIANCE ORDER FILED 9/29/98. COMPLAINT ALLEGES: COUNT I RESPONDENTS EXCEEDED LIMITS ESTABLISHED IN THEIR FACILITY'S PART A HAZARDOUS WASTE APPLICATION FROM 1993 TO 1996. IN VIOLATION OF RCRA 40 C.F.R. SECTION 270.71(A)(3) AND TENNESSEE RULE (TR) 1200-1-11-07(3)((B)(1). COUNT II RESPONDENTS FAILED TO PROVIDE TRAINING TO PERSONNEL AND PROVIDE DOCUMENTATION IN ACCORDANCE WITH 40 C.F.R. SECTION 265.16. IN VIOLATION OF RCRA 40 C.F.R. SECTION 265.16 AND TR 1200-1-11-05(2)(G). COUNT III RESPONDENTS FAILED TO MAINTAIN THE OB/OD INTERIM STATUS UNIT TO PREVENT UNKNOWING ENTRY, AND MINIMIZE THE POSSIBILITY FOR THE UNAUTHORIZED ENTRY, OF PERSONS OR LIVESTOCK ONTO THE UNIT FOR AT LEAST THREE YEARS PRIOR TO THE INSPECTION. IN VIOLATION OF RCRA 40 C.F.R. SECTION 265.14(A) . COUNT IV RESPONDENTS FAILED TO INSPECT AND HAVE RECORDED INSPECTIONS OF THE OB/OD INTERIM STATUS UNIT FOR AT LEAST THREE YEARS PRIOR TO THE INSPECTION. IN VIOLATION OF RCRA 40 C.F.R. SECTION 265.15, AND TR 1200-1-11-05(2)(F). COUNT V RESPONDENTS HAVE EITHER ISOLATED, DE