Consent Agreement and Final Order ( CA/FO ), pursuant to 40 C.F.R. 22.13 and 22.18, simultaneously commences and concludes this proceeding, wherein EPA alleges that Respondent violated Section 3008 of RCRA, 42 U.S.C. 6928, and state regulations adopted pursuant to the approved California hazardous waste management program. Respondent failure to make a HW determination, failure to label HW containers, failure to close HW storage containers, failure to provide adequate aisle space, failure to retain copies of signed HW manifests, failure to properly dispose of HW, and failure to comply with HW training requirements. Respondent admits and agrees that EPA has jurisdiction and authority over the subject matter of the action commenced in this CAFO and over Respondent. Respondent will develop a hazardous waste determination Standard Operating Procedure (SOP) within ninety (90) days of the Effective Date of the CA/FO.