ON JUNE 8, 2011, RESPONDENT FAILED TO QUALIFY FOR THE LESS THAN 90 DAY GENERATOR ACCUMULATION EXEMPTION OF COMAR 26.13.03.05E, BY FAILING TO SATISFY THE CONDITIONS FOR THE EXEMPTION AS SET FORTH IN COMAR 26.13.03.05E.
FROM MAY 17, 2010 TO OCTOBER 18, 2010 AND FROM OCTOBER 18, 2010 TO MARCH 14, 2011, RESPONDENT STORED HAZARDOUS WASTE AT THE FACILITY WITHOUT A PERMIT, INTERIM STATUS OR VALID EXEMPTION, IN VIOLATION OF COMAR 26.13.07.01A AND SECTION 3005A OF RCRA, 42 U.S.C. SECTION 6925(a).
ON JUNE 8, 2011, RESPONDENT VIOLATED COMAR 26.13.05.09D BY FAILING TO KEEP CONTAINERS HOLDING HAZARDOUS WASTE CLOSED DURING STORAGE, EXCEPT WHEN IT IS NECESSARY TO ADD OR REMOVE WASTE.
RESPONDENT VIOLATED COMAR 26.13.03.02 BY DISPOSING OF WASTE AEROSOL CANS AND WASTE FLUORESCENT LIGH TBULBS GENERATED AT THE FACILITY WITHOUT FIRST DETERMINING WHETHER SUCH WASTE IS HAZARDOUS USING ONE OF THE METHODS SET FORTH IN COMAR 26 13.03.02.
FROM AT LEAST JUNE 8, 2008 THROUGH JUNE 8, 2011, RESPONDENT FAILED TO CONDUCT WEEKLY IMSPECTIONS OF THE HAZARDOUS WASTE STORAGE AREA AT THE FACILITY.
FROM AT LEAST JUNE 8, THROUGH JUNE 8, 2011, RESPONDENT VIOLATED COMAR 26.13.05.09E BY FAILING TO CONDUCT WEEKLY INSPECTIONS OF THE HAZARDOUS WASTE STORAGE AREA AT THE FACILITY.
RESPONDENT FAILED TO MAINTAIN THE DOCUMENTATION REQUIRED BY COMAR 26.13.05.02G(4)(a)-(c): 1) THE JOB TITLE FOR EACH POSITION AT THE FACILITY RELATED TO HAZARDOUS WASTE MANAGEMENT, AND THE NAME OF THE EMPLOYEE FILLING EACH SUCH