Duly authorized representatives of EPA and the Pennsylvania Department of Environmental Protection ( PADEP ), respectively, conducted a compliance evaluation inspection ta the Facility on February 1, and 2, 2001. At the time of the February 1 and 2, 2001 EPA/PADEP inspection, Respondent U.S. Chrome Corporation of Pennsylvania owned and maintained seven (7) existing hard chromium electroplating tanks at the Facility and five (5) of these existing hard chromium electroplating tanks were operated by the Respondent, each utilizing a hexavalent chromium bath. During the February 1, and 2, 2001 EPA/PADEP inspection, the EPA inspector determined that the Respondent was not in compliance with certain of the reporting, work practice standard, and record keeping requirements of the Chrome Plating NESHAP. He further observed that U.S. Chrome was improperly storing RCRA hazardous wastes at the facility and referred this matter to EPA Region III's Waste & Chemical Management Division for further investigation. As a result, duly authorized representatives of EPA and PADEP conducted follow-up compliance evaluation inspections at the Facility on February 20 and 22, 2001 in order to assess further the Facility's compliance with Subtitle C of RCRA. At that time, the EPA inspector observed numerous violations of RCRA Subtitle C and of the applicable PaHWMR. The Regional formally notified U.S. Chrome of these violations, as enumerated below, and of EPA's determination to initiate civil pen