On September 29, 2004, Region 5 filed a combination Complaint/Consent Agreement and Final Order simultaneously initiating and resolving an administrative penalty and compliance action against the University of Illinois (U of I) in Urbana, Illinois. The Region alleged that U of I committed violations of RCRA-authorized state hazardous waste requirements applicable to accumulated and stored hazardous wastes in the a ���less than 90 day waste accumulation area��� which was a fenced-in area on a concrete pad outside the Roger Adams Laboratory on the UofI main campus. The requirements at issue include marking, inspection, contingency plan and training requirements. The violations occurred due to
Respondent��� belief that the area at issue was not a less than 90 day waste accumulation area, but instead a satellite storage area. Ten prior inspections of the area had not identified the violations. After receipt of the Region���s Notice of Violation regarding the violations, UofI promptly and co-operatively came into compliance, and in the CAFO certifies that it is in compliance with the requirements that formed the basis of the allegations of violation. Respondent took the following steps: conducted personnel training for those persons who managed hazardous waste by transporting the waste to the area at issue; ceased all storage of hazardous waste at the area; and dismantled the storage structure at the area, and now accumulates and stores the hazardou