This is an Administrative Penalty complaint and consent agreement pursuant to RCRA Subtitle C which simultaneously initiates and concludes this action with respect to Concorde Garment Manufacturing Corp. The violations alleged are Count 1: Failure to make a hazardous waste determination in violation of 40 C.F.R. § 262.11; Count 2: Failure to meet container management requirements in violation of 40 C.F.R. § 265.173; Count 3: Offering waste to a transporter and TSD without an EPA ID number in violation of 40 C.F.R. §§ 262.12(c); Count 4: Failure to prepare a hazardous waste manifest in violation of 40 C.F.R. § 262.20; Count 5: Failure to ensure that employees are familiar with waste handling procedure in violation of 40 C.F.R. § 262.34(d);Count 6: Storage of hazardous waste without a permit in violation of 40 C.F.R. §§ 262.34(a) and 270.1. The Respondent has agreed to pay penalty of $15,200 and perform a Supplemental Environmental Project (SEP) valued at $56,000.