In May 2008, RCRA compliance evaluation inspections were conducted of several sites owned and operated by the Respondent. The City manages approximately 40 buildings, conducts street maintenance activity, maintains a fleet of more than 1,000 vehicles, collects and disposes of municipal wastes, and conducts other municipal operations. As a result of the inspections, City officials conceded that it had routinely disposed of its significant quantity of spent mercury lamps, a potentially hazardous waste, as regular trash. A complaint was issued on March 31, 2009 citing the City's failure to make a hazardous waste determination and for not responding to several RCRA 3007 Information Request Letters. The City agreed to pay a penalty and to implement a resident recycling program for spent fluorescent lamps, light ballasts, and other e-wastes.