This Administrative Order on Consent ( AOC or Order ) is entered into upon mutual
agreement by the parties, EPA Region IX and the Department of Public Works of Imperial
County, CA ( Respondent ). Accordingly, although Respondent neither admits nor denies
EPA' s specific factual allegations herein, Respondent admits to and agrees not to contest EPA' s
jurisdiction to issue this Order or enforce its terms. Further, Respondent will not contest EPA's
jurisdiction to: compel compliance with this Order in any subsequent enforcement proceedings,
either administrative or judicial; require Respondent's full compliance with the terms of this
Order; or impose sanctions for violations of this Order.EPA makes the following Findings for violations of the Solid Waste Disposal Act, as
amended by the Resource Conservation and Recovery Act and the Hazardous and Solid
Waste Amendments of 1984 (hereinafter, RCRA ), Sections 4004 and 4005(a), 42 U.S.C.
�� 6944 and 6945(a), as well as 40 C.F.R. Part 258. EPA is issuing this Order pursuant to
Sections 4005(c)(2) and 3008(a) ofRCRA, 42 U.S.C. �� 6945(c)(2) and 6928(a), and the
Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties,
Issuance of Compliance or Corrective Action Orders, and the Revocation, Termination or
Suspension of Permits, 40 C.F.R. Part 22 ( Part 22 ).