On October 4, 2017, Region 5 filed a Consent Agreement and Final Order (CAFO) with Heritage Environmental Services, LLC (Heritage), commencing and concluding an administrative proceeding under Section 3008(a) of the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. 6928(a), for alleged violations of Heritage?s hazardous waste storage permit, the Indiana Administrative Code (IAC), and 40 C.F.R. Parts 264 and 268 at its Indianapolis facility. Heritage is an Indiana corporation with approximately 1,000 employees and annual revenues totaling between $100mm to $124mm; it treats and stores hazardous waste at the Indianapolis facility and operates a Subtitle C landfill in Roachdale, Indiana. Region 5 initiated this action in July 2012 by conducting a RCRA inspection of the Indianapolis facility. (Indiana has an approved RCRA program and was notified of this action.) Heritage violated its permit, the Indiana Administrative Code, and RCRA and its implementing regulations by (1) disposing of hazardous waste in the Roachdale landfill without meeting certain land disposal restriction (LDR) treatment standards; (2) failing to conduct post-treatment verification sampling and analysis of certain wastestreams from two stabilization/LDR treatment processes; (3) failing to obtain a detailed chemical and physical analysis of representative samples from such wastestreams; (4) failing to follow the acceptable analytical methods in its waste analysis plan (WAP); and (5) failing to determine