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, between the years 2018 and 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.