ON OCTOBER 23, 2014, REGION III FILED A CONSENT AGREEMENT AND FINAL ORDER ( CAFO ) FOR VIOLATIONS OF PENNSYLVANIA HAZARDOUS WASTE MANAGEMENT REGULATIONS, WHICH PENNSYLVANIA ADMINISTERS IN LIEU OF THE FEDERAL HAZARDOUS WASTE MANAGEMENT PROGRAM ESTABLISHED BY RCRA SUBTITLE C. AT ITS FACILITY IN CHESTER, PENNSYLVANIA, NORQUAY TECHNOLOGY CORPORATION ( NORQUAY ) WAS STORING, TREATING AND DISPOING OF HAZARDOUS WASTE WITHOUT A PERMIT OR INTERIM STATUS TO OPERATE A HAZARDOUS WASTE TREATMENT, STORAGE AND DISPOSAL ( TSD ) FACILITY. IN ADDITION TO OPERATING A TSD FACILITY WITHOUT A PERMIT OR INTERIM STATUS, NORQUAT FAILED TO MAKE HAZARDOUS WASTE DETERMINATIONS FOR CERTAIN LABORATORY CHEMICALS AND SPENT SOLVENTS, FAILED TO KEEP HAZARDOUS WASTE CONTAINERS CLOSED DURING STORAGE EXCEPT WHEN NECESSARY TO ADD OR REMOVE WASTE, FAILED TO PROVIDE REQUIRED HAZARDOUS WASTE TRAINING TO CERTAIN EMPLOYEES, FAILED TO MAINTAIN HAZARDOUS WASTE TRAINING RECORDS FOR CERTAIN EMPLOYEES, FAILED TO MAINTAIN LDR FORMS, AND FAILED TO COMPLY WITH HAZARDOUS WASTE MANAGEMENT REQUIREMENTS AND PAY A CIVIL PENALTY.