ON 05/09/91, EPA PERFORMED AN INSPECTION OF RESPONDENT'S FACILITY. DURING THE INSPECTION, THE EPA INSPECTORS OBSERVED THE FOLLOWING: RESPONDENT HAD BEEN PURCHASING CHLORINATED SOLVENTS SINCE AT LEAST 1985; RESPONDENT HAD BEEN PLACING SPENT CHLORINATED SOLVENTS IN ITS WASTE OIL TANK (ALONG WITH WASTE OIL); RESPONDENT MADE AT LEAST 23 SHIPMENTS OF ITS SPENT SOLVENTS TO A USED OIL RECLAIMER; RESPONDENT HAD NOT COMPLETED A UNIFORM HAZARDOUS WASTE MANIFEST FOR ANY OF THE SHIPMENTS; RESPONDENT HAD FAILED TO SEND A LAND DISPOSAL RESTRICTION NOTIFICATION WITH EACH SHIPMENT OF HAZARDOUS WASTE; THE F001 AND F002 HAZARDOUS WASTE WAS BEING STORED AT THE FACILITY IN A TANK THAT DID NOT MEET THE REQUIREMENTS OF 40/265; RESPONDENT MADE 23 SHIPMENTS OF RCRA HAZARDOUS WASTE TO APPROVED OIL. APPROVED OIL HAD NEITHER A PERMIT NOR INTERIM STATUS TO TREAT, STORE, OR DISPOSE OF RESPONDENT'S HAZARDOUS WASTE. THERE ARE 71 COUNTS TO THIS CASE WITH A COMBINED PROPOSED CIVIL PENALTY OF $1,831,000.