DURING EPA INSPECTIONS CONDUCTED AT THE FACILITY ON AUGUST 4, 2009 AND FEBRUARY 9, 2011, EPA INSPECTORS OBSERVED FACILITY CONDITIONS AND OPERATING PRACTICES WHICH INDICATED THAT HAZARDOUS WASTE HAD BEEN RELEASED FROM THE FACILITY AND THAT HAZARDOUS WASTE AND/OR HAZARDOUS WASTE CONSTITUENTS MAY HAVE MIGRATED TO SUB-SURFACE SOIL, SURFACE WATERS OR GROUND WATERS AND MAY PRESENT A SUBSTANTIAL RISK TO HUMAN HEALT OR THE ENVIRONMENT. DURING EACH OF THE TWO EPA INSPECTIONS, THE FACILITY WAS NOT IN COMPLIANCE WITH RCRA REQUIREMENTS FOR GENERATORS OF HAZARDOUS WASTE. ALTHOUGH THE FACILITY HAS COME INTO COMPLIANCE WITH THE RCRA REQUIREMENTS SINCE THE TIME OF EPA'S INSPECTIONS, PAST NONCOMPLIANCE WITH RCRA REQUIREMENTS CAUSED RELEASES OF HAZARDOUS WASTE AND POTENTIAL MIGRATION TO SUB-SURFACE SOIL, SURFACE WATERS OR GROUND WATERS THAT WARRANTS INVESTIGATION.