The Solvay USA CAFO resolved alleged violations of RCRA by Solvay USA Inc. (Solvay USA or the facility), a large quantity generator of hazardous waste located in University Park, Illinois. The facility produces amphoterics, preservatives, performance concentrates/blends, glycol esters, amides/amidoamines/oxides, quats and sulfosuccinates for the Solvay Novecare global business unit. EPA?s allegations were based on information and documents provided by Solvay USA during an IEPA inspection on April 29, 2014 and in response to an IEPA Notice of Violation, an EPA Request for Information, a Pre-Filing Notice and Opportunity to Confer Letter (Pre-Filing Letter), and to pre-filing settlement discussions. IEPA referred the facility to EPA on October 20, 2014. The CAFO was issued for a violation concerning the failure to conduct hazardous waste determinations or retain determination records, and storage of hazardous waste without a permit or interim status by failing to meet the following permit exemption conditions: storing hazardous waste for over 90 days; failing to mark or label hazardous waste containers with the words, ?Hazardous Waste?; failing to mark hazardous waste containers with an accumulation start date; failure to maintain aisle space in the hazardous waste storage area; failure to conduct weekly inspections of the hazardous waste storage area, and failure to train employees. Solvay will pay a $200,000 cash penalty and spend a minimum of $250,000 for two Supplemental