Respondent operates a heparin (blood anticoagulant) manufacturing facility in Oelwein, IA. EPA inspected the facility on February 17, 2020. At the time of inspection, the following conditions for exemption from permitting requirements for a large quantity generator were not met: a) having and maintaining a contingency plan and quick reference guide; b) conducting and documenting hazardous waste training; and c) compliance with Subpart BB (failure to mark equipment and keep records). As a result of these deficiencies, Respondent was operating a treatment, storage and disposal facility without a permit, and failed to comply with the operator requirements set forth above. The case was resolved for $80,562. This case falls within the RCRA Air NCI/NSI.