AK Steel Corporation produces steel at the Facility using two electric arc furnaces, which results in the formation of emission control dust with hazardous waste number K061. The Region alleged in a Notice of Intent to File Civil Administrative Complaint and Notice of Violation issued October 17, 2012 (?NOI/NOV?), that AK Steel was an operator of a hazardous waste storage facility for which a hazardous waste storage permit had not been requested or received, based on AK Steel?s alleged failure to comply with the conditions for the generator exemption from the requirement to have a hazardous waste permit in the following ways: (1) failure to include all required elements in its program of on-the-job training; (2) failure to satisfy all requirements for the facility contingency plan; (3) failure to make arrangements to familiarize police, fire departments, and emergency response teams with the facility, its operations and the hazardous waste handled at the facility; (4) failure to inspect hazardous waste storage areas; and (5) failure to maintain and operate the facility to minimize the possibility of an unplanned or non-sudden release of K061, Electric Arc Furnace dust, to the air, soil or surface water that could threaten human health or the environment. In addition, the NOI/NOV alleged that AK Steel had improperly stored used fluorescent light bulbs in two containers in violation of the universal waste requirements. AK Steel has agreed to resolve this matter with the payment