EPA has determined that Respondent failed to have an EPA identification number prior to transporting or offering for transport hazardous waste from its Facility. Specifically, during the years 2018-2021 Respondent shipped hazardous waste from its Facility using hazardous waste manifest(s) without having received an EPA identification number in violation of Title 6 N.Y.C.R.R. Section 372.2(a)(3). In signing this Agreement, Respondent: (1) admits that it is subject to RCRA and New York State's authorized hazardous waste program; (2) admits that EPA has jurisdiction over Respondent and Respondent's conduct as described herein; (3) neither admits nor denies the allegations contained herein; (4) consents to the assessment of this penalty; (5) waives the opportunity for a hearing pursuant to Section 3008(b) of RCRA to contest any issue of fact or law set forth herein; (6) waives its right to appeal the Final Order accompanying this Agreement; and (7) consents to electronic service of the final Agreement.