In this CAFO, EPA cited IHT for failure to obtain a RCRA permit or interim status. This action is based on IHTÂs failure to comply with certain conditions for the generator exemption which resulted in IHT becoming an operator of a hazardous waste storage facility. Specifically, EPA cited that Respondent failed to properly mark satellite containers of hazardous waste, failed to store hazardous waste containers closed, and stored hazardous waste in containers without proper labeling. Furthermore, EPA cited that Respondent violated the hazardous waste storage facility requirements when it failed to: (1) meet certain training requirements; (2) meet certain contingency plan requirements; (3) minimize the risk to human health and the environment; and (4) store hazardous waste for 90 days or less on four occasions. Lastly, EPA alleges that IHT failed to comply with certain generator requirements, i.e. failure to conduct waste determinations, manifest requirements and exception reports.