This is a civil administrative enforcement action instituted pursuant to Section 3008 of the Resource Conservation and Recovery Act ( RCRA ), as amended, 42 U.S.C. Section 6928, and the Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties ad the Revocation/Termination or Suspension of Permits, Title 40 of the Code of Federal Regulations ( 40 CFR ) Part 22, ( Consolidated Rules ). Respondent agrees to pay $25,000 as the penalty for the violations. In executing this CAFO, Respondent certifies under penalty of law to EPA that it has fully complied with Section 3008 of RCRA, 42 U.S.C. Section 6928, and its implementing regulations, as well as the applicable permit requirements pertaining to the alleged violations.