On March 16, 2006, Region 5 filed an Administrative Complaint, and Consent Agreement and Final Order (CAFO) with Eco Clean, Incorporated (Eco Clean) at its Raymond, Illinois facility. The Region alleged that Eco Clean was storing hazardous waste without a permit or interim status by storing hazardous waste in an unsecured trailer on a residential street outside its facility boundaries. Eco Clean was subject to a penalty of $247,500. After Region 5 issued a Show Cause letter, Eco Clean raised an ability to pay issue and provided financial documents for Region 5 to evaluate. Region 5 evaluated Eco Cleanýs financial documentation using an outside contractor and determined that a $7,800 penalty was warranted. Region 5 and Eco Clean then entered settlement negotiations. The CAFO requires Eco Clean to pay a civil penalty of $7,020.