-ACCUMULATION AND STORAGE OF HAZARDOUS WASTE AT ARVADA FACILITY FOR LONGER THAN 90 DAYS WITHOUT A HAZARDOUS WASTE PERMIT OR INTERIM STATUS. -OFFERING AND ACCEPTING HAZARDOUS WASTE FOR TRANSPORT, TRANSPORTING HAZARDOUS WASTE WITHOUT A SIGNED MANIFEST, AND FAILURE TO RETAIN MANIFEST RECORDS ON-SITE FOR REQUIRED TIME -STORAGE OF HAZRDOUS WASTE AT THE GRAND JUNCTION FACILITY WITHOUT A PERMIT OR INTERIM STATUS. -FAILURE AT BOTH FACILITIES TO STORE HAZARDOUS WASTE ACCORDING TO REQUIREMENTS. -DISPOSAL OF HAZARDOUS WASTE AT THE ARVADA AND GRAND JUNCTION FACILITIES BY SPILLING, PLACING, POURING OR DUMPING SUCH WASTES ON THE GROUND, AND/OR IN A DRUM RECLAMATION BURNER, WITHOUT ANY AUTHORIZING PERMIT GRANTED PURSUANT TO RCRA OR ANY OTHER STATUTE, AND WITHOUT INTERIM PERMIT STATUS -FAILURE TO DETERMINE IF THE RESIDUAL LIQUIDS FROM IN- COMING DRUMS ARE HAZARDOUS WASTE. -FAILURE TO PREPARE AND SUBMIT ANY REQUIRED BIENNIAL REPORTS TO EPA.