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 and the Revocation/Termination or Suspension of Permits, Title 40 of the Code of Federal Regulations ( C.F.R. ) Part 22 ( Consolidated Rules ). Respondent is Genentech, Inc. This Consent Agreement and Final Order ( CA/FO ), pursuant to 40 C.F.R. Section 22.13(6) and 22.18 simultaneously commences and concludes this proceeding, wherein EPA alleges that Respondent violated state regulations adopted pursuant to the approved California hazardous waste management program.