On September 25, 2014, Region 5 filed a Consent Agreement and Final Order (CAFO) commencing and resolving simultaneously an administrative penalty action against Respondent Harold Marcus Limited (Harold Marcus), a trucking company engaged in the business of transporting hazardous waste in the United States and Canada. The CAFO provides for payment of a $8,415 penalty by Harold Marcus for violations of federal and state hazardous waste management regulations promulgated pursuant to the Resource Conservation and Recovery Act of 1976, as amended (RCRA), 42 U.S.C. § 6901 et seq. Specifically, Region 5 alleges that on three occasions in July 2011, Harold Marcus had accepted hazardous waste from a generator in Illinois for transport and export to Canada without ensuring that the manifest documentation included an EPA Acknowledgement of Consent form that indicated that Canada had approved the export, in violation of the provisions of 40 C.F.R. § 263.20 and analogous Illinois regulations. In addition, Region 5 alleges that for two of these shipments, Harold Marcus had failed to retain the hazardous waste manifest records as required by the provisions of 40 C.F.R. §§ 263.20 and 262.2