The U.S. Environmental Protection Agency ( EPA ) is authorized to enter into this Expedited Settlement Agreement ( Agreement ) pursuant to Section 3008 and 4005(d) of the Resource Conservation and Recovery Act ( RCRA ) and 40 C.F.R. Section 22.13(b). GF Industries, LLC dba The Gun Range San Diego ( Respondent ) is the owner or operator of the facility. EPA alleges that the Respondent violated the requirements of the RCRA and EPA approved and authorized California Hazardous waste management programs.