THE FACILITY FAILED TO TIMELY CONDUCT AN INITIAL INSPECTION AS REQUIRED BY 40 C.F.R. PART 264, SUBPART CC. IMPACT: ON SEPTEMBER 25, 2000, U.S. EPA FILED A FULLY EXECUTED CAFO TO SETTLE THE ADMINISTRATIVE PROCEEDING. BACKGROUND: RESPONDENT, SAFETY KLEEN SYSTEMS, INC., OWNS AND OPERATES A PERMITTED HAZARDOUS WASTE STORAGE FACILITY LOCATED IN BLAINE, MN. ON DECEMBER 17, 1998, U.S. EPA PER- FORMED A RCRA COMPLIANCE INSPECTION AT THE FACILITY AND DISCOVERED THAT RESPONDENT WAS NOT IN COMPLIANCE WITH 40 C.F.R. PART 265, SUBPART CC INITIAL INSPECTION REQUIREMENTS. BASED ON RESPONDENT'S FAILURE TO COMPLY WITH THE SUBPART CC REQUIREMENTS, U.S. EPA ISSUED A ONE-COUNT COMPLAINT ON SEPTEMBER 24, 1999, AND PROPOSED A PENALTY OF $39,300. AFTER RESPONDENT SUBMITTED ITS ANSWER, U.S. EPA AND THE RESPONDENT AGREED TO SETTLE THE CASE. BASED ON NEW FACTS DISCOVERED DURING THE SETTLEMENT DISCUSSIONS, U.S. EPA MITIGATED THE PROPOSED PENALTY TO $31,440. THE RESPONDENT AGREED TP PAY THE PROPOSED PENALTY IN CASH.