Region 5 filed a Consent Agreement and Final Order (CAFO) commencing and concluding an administrative matter under Section 3008(a) of the Resource Conservation and Recovery Act (RCRA) with Western Illinois University (WIU), a corporation doing business in Moline, Illinois. WIU generates hazardous waste in its labs that conduct chemistry and biology research and teaching. The CAFO alleges that WIU was a generator of hazardous waste that: a) had stored hazardous waste for more than 90 days; b) had stored hazardous waste in containers that were not marked with the start date of accumulation; c) had not marked or labeled containers holding hazardous waste clearly with the words ?Hazardous Waste?; d) had not tested and maintained fire protection equipment to assure its proper operation in time of an emergency; e) had not amended the contingency plan when the list of emergency coordinators changed; f) had not inspected areas where containers were stored at least weekly; and g) had not provided facility personnel with the initial required RCRA training, without applying for or obtaining a permit, in violation of Section 3005 of RCRA, 42 U.S.C. ? 6925(a) and the requirements of 35 Ill. Adm. Code ?? 703.121, 703.180, and 705.121. The CAFO further alleges that WIU failed to make a determination as to whether waste being stored in numerous containers was hazardous waste, in violation of 35 Ill. Adm. Code ? 722.111, and that WIU had not retained on-site a copy of the
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