Harmon Electronics, Inc. appeals from an Initial Decision assessing a civil penalty of $586,716 for various violations of the requirements of Missouri’s authorized program under the Resource Conservation and Recovery Act (“RCRA”), 42 U.S.C. §§ 6901-6992(k). The complainant is U.S. EPA Region VII. The violations alleged in the Region’s complaint relate to Harmon’s unpermitted disposal of hazardous waste at Harmon’s facility in Grain Valley, Missouri. Between 1973 and 1987 Harmon’s employees disposed of various organic solvents by pouring them out the back door of the facility.