PROFESSIONAL TANK LINING, INC. IS ENGAGED IN THE BUSINESS OF COATING THE INTERIO RO UNDERGROUND STORAGE TANKS WITH PROTECTIVE LINERS. RESPONDENT EMPTIES THE SLUDGE OUT OF EACH TANK BEFORE LINING THE TANK. ON SEPTEMBER 18, 1991, EPA INSPECTED A FACILITY OWNED BY WAYNE CHADDOCK AND DISCOVERED AT LEAST 19 55-GALLON DRUMS OF D001 HAZARDOUS WASTE AT WAYNE'S FACILITY, WHICH RESPONDENT HAD TRANSPORTED WITHOUT NOTIFYING EPA, OBTAINING AN EPA IDENTIFICATION NUMBER AND WITHOUT AN ACCOMPNAYING HAZARDOUS WASTE MANIFEST. BASED ON ABOVE EVIDENCE, EPA IS ISSUING AN ADMINISTRATIVE COMPLAINT, REQUESTING $18,000 IN PENALTIES FOR THESE VIOLATIONS.