On September 14, 2016, Region III entered into a Consent Agreement with, and issued a Final Order to Dana Container, Inc. ( Dana ), settling violations of RCRA Subtitle C that EPA inspectors observed during an inspection of the company's facility located in Wilmington, Delaware ( Facility ). Dana cleans and refurbishes rail cars at the Facility. During the inspection, and through subsequent communications, the EPA Inspector learned that Dana: (1) failed to comply with several permit exemption conditions and therefore operated the Facility without a permit, (2) failed to retain as a record two hazardous waste manifests with the signatures of representatives from the designated receiving facilities that received the associated hazardous waste, or failed to prepare or retain exception reports for these shipments, (3) failed to have adequate personnel records which describe hazardous waste management duties and training to be provided to employees with hazardous waste management responsibilities, (4) failed to maintain an adequate contingency plan, and (5) failed to properly manage universal waste lamps in labeled and closed containers. Dana has agreed to pay a penalty of $12,000.00 to settle the enforcement action. The Consent Agreement and Final Order initiate and resolve this enforcement action.