Chem-Solv, Inc. (“Chem-Solv”) and Austin Holdings-VA, LLC (“Austin Holdings”) appeal from an Initial Decision issued by Administrative Law, Judge Susan L. Biro (“ALJ”) in an administrative enforcement action brought by U.S. EPA Region III (“Region”) for violations of Subtitle C of the Resource Conservation and Recovery Act (“RCRA”), 42 U.S.C. §§ 6921-6939e, and the Commonwealth of Virginia’s federally authorized hazardous waste management program. The alleged violations occurred at Chem-Solv’s chemical blending and distribution facility in Roanoke, Virginia.