Region 5 filed a Consent Agreement and Final Order (CAFO) commencing and concluding an action against Southern Illinois University. At the time of Illinois EPA's inspection on August 8, 2012 through August 10, 2012, it was a public research university with approximately 700 onsite laboratories and it was located in Carbondale, Illinois. SIU's laboratory processes generated laboratory hazardous wastes and hazardous lamp waste. SIU allegedly violated the Resource Conservation and Recovery Act (RCRA) by: (1) failing to mark containers of hazardous waste with accumulation start dates in violation of 40 C.F.R. 262.34(a)(2); (2) failing to label containers with the words Hazardous Waste in violation of 40 C.F.R. 262.34(a)(3); (3) failing to have information regarding spill control equipment and emergency plan information as required by 40 CFR 265.52; (4) failing to have telephones for emergency communications as required by 40 CFR 265.32 and 265.34; and (5) failing to provide hazardous waste training for employees as required by 40 C.F.R. 265.16(a). SIU thereby violated 40 C.F.R. Part 270 and Section 3005 of RCRA, 42 U.S.C. 6925(a), by failing to meet all conditions for an exemption from a RCRA permit. SIU also allegedly violated RCRA by: (1) failing to include hazardous waste sent offsite for disposal on their annual report to the Illinois EPA for its calendar year 2012 generator activities in violation of 40 C.F.R. 262.41; and (2) failing to make several hazardous waste determ