The U.S. Environmental Protection Agency conducted inspections at Specified Plating Company (Specified Plating) on January 30 and February 18, 2009, in order to evaluate Specified Plating's compliance with the Illinois regulations for hazardous waste generators promulgated under the Resource Conservation and Recovery Act (RCRA). As a result of those inspections, the EPA determined that Specified Plating had failed to: (1) Conduct a hazardous waste determination on a solid waste stream generated at the facility; (2) Comply with the time limit restrictions for generators storing hazardous waste without a permit; and (3) Provide RCRA training to employees with duties involving hazardous waste management in the years 2006 and 2007, as well as maintain adequate training records. The EPA had initially alleged several additional violations related to container management and contingency planning, which were later dropped based on relevant information provided by Specified Plating.
On August 5, 2010, the EPA notified Specified Plating of its intent to file an Administrative Complaint seeking civil penalties. In its notice, the EPA proposed to seek a penalty of $66,400 for the alleged violations. Settlement negotiations commenced, and the EPA and Specified Plating agreed to settle the matter through the filing of a Consent Agreement and Final Order (CAFO). The terms of settlement require Specified Plating to pay a civil penalty of $5,000. The reduced penalty agreed upon in se