CSI is the owner and operator of a solvent reclamation, chemical blending, and commodity chemical business at a facility in southern Cleveland that includes adjacent buildings at 3751 Jennings Road (Jennings) and 1010 Old Denison Road (Denison). The facility operates under a Federally Enforceable Permit to Install and Operate (FEPTIO) for air emissions issued by Ohio EPA, a RCRA air permit issued by EPA, a RCRA permit for treatment and storage of hazardous waste issued by Ohio EPA, and administrative orders (AOs) for wastewater discharge into the public sewer issued by the Northeast Ohio Regional Sewer District (NEORSD). CSI emits hazardous air pollutants (HAPs) and volatile organic compounds (VOCs) at both Jennings and Denison. EPA alleges that CSI violated RCRA and CAA air emission requirements by failing to: properly control its organic emissions from process vents, tanks, and equipment leaks; meet closed-vent system requirements, including control device monitoring, flow monitoring, routing emissions to a control device, daily inspection and corrective measure requirements, and recordkeeping; secure and control organic emissions from fixed roof tanks; and properly calibrate air monitoring equipment. EPA alleges that CSI violated RCRA requirements by failing to maintain its facility to minimize the possibility of a release of hazardous waste or hazardous waste constituents, including holes and corrosion in tanks, storing flammable waste near oxidizers, inadequate secondary