This CAFO simultaneously commenced and concluded an administrative action alleging violations of the RCRA regulations at 40 C.F.R. ?? 262.34(a) - (c), regarding the conditions that
a generator of hazardous waste must comply with if they do not have a RCRA permit or interim status. On July 17, 2015, EPA conducted a compliance inspection at the Elk Grove Village facility. The State of Illinois was invited to participate in this inspection but did not do so. A Notice of Violation (?NOV?) was sent to Circuit Engineering on April 13, 2016, and a Notice of Intent to File an Administrative Complaint was sent to Circuit Engineering on February 15, 2017. These documents alleged violations of RCRA?s: hazardous waste container dating and labeling requirements; hazardous waste storage tank requirements; personnel training requirements; and hazardous waste recordkeeping and reporting.