Consent Agreement and Final Order ( CA/FO ), pursuant to section 3008(a)(1) of the Resource Conservation and Recovery Act ( RCRA ). EPA alleges the following violations for the respondent: failure to make an accurate waste determination, operating without a permit; failure to maintain and operate the facility to minimize the possibility of an unplanned release, failure to properly manage satellite accumulation area hazardous waste containers. Respondent agrees to pay a civil penalty in the amount of fifty thousand dollars within thirty calendar days of the Effective Date of this CA/FO.