THIS ENFORCEMENT ACTION ADDRESS CWA AND RCRA VIOLATIONS DISCOVERED DURING EPA INSPECTIONS CONDUCTED ON MAY 2008 AND JUNE 2009. EPA SEEKING A PENALTY FOR THE VIOLATIONS, AS WELL, REQUIRING THE FACILITY TO SUBMIT A REVISED PERMIT APPLICATION TO ADDRESS DISCHARGES OF ALL STORMWATER AND/OR PROCESS WATER THAT ARE NOT COVERED BY ITS EXISTING PERMIT.