The United States Environmental Protection Agency, Region IX ( EPA ) and U.S. Ecology Nevada, Inc. ( USEN or Respondent ) agree to settle this case initiated under the Resource Conservation and Recovery Act ( RCRA ), 42 U.S.C. Sections 6901 et seq., and the Toxic Substances Control Act ( TSCA ), 15 U.S.C. Sections 2601 et seq., and consent to the entry of this Consent Agreement and Final Order ( CAFO ), which simultaneously commences and concludes this matter pursuant to 40 C.F.R. Sections 22.13 and 22.18. Respondents agree to pay a civil penalty of $185,429 for the violations.