J.V. Peters and Company, a partnership, David B. Shillman, and Dorothy L. Brueggemeyer (collectively, “Respondents”) have appealed an initial decision by Administrative Law Judge Gerald Harwood (the “Presiding Officer”) assessing a civil penalty against them jointly and severally in the amount of $23,500 for numerous violations of section 3004 of the Resource Conservation and Recovery Act (“RCRA”), 42 U.S.C. § 6924. The violations were observed during inspections of Respondents’ Middlefield Township, Ohio hazardous waste storage and reclamation facility (“the facility”) in December 1980.