ON AUGUST 23, 2012, REGION III FILED CONSENT AGREEMENT AND FINAL ORDER ( CAFO ) FOR VIOLATIONS OF PENNSYLVANIA'S HAZARDOUS WASTE MANAGEMENT REGULATIONS, WHICH PENNSYLVANIA ADMINISTERS IN LIEU OF THE FEDERAL HAZAREDOUS WASTE MANAGEMENT REGULATIONS, WHICH PENNSYLVANIA ADMINISTERS IN LIEU OF THE FEDERAL HAZARDOUS WASTE MANAGEMENT PROGRAM ESTABLISHED BY RCRA SUBTITLE C. AT IS FACILITY IN GLENN ROCK, PENNSYLVANIA, BIMAX WAS STORING HAZARDOUS WASTE WITHOUT MEETING EITHER THE 90-DAY STORAGE OR SATELLITE ACCUMULATION EXEMPTIONS, OR ACQUIRING A PERMIT OR INTERIM STATUTS TO OPERATE A HAZARDOUS WASTE STORAGE FACILITY. IN ADDITION TO OPERATING A HAZAREDOUS WASTE STORAGE FACILITY WITHOUT A PERMIT OR INTERIM STATUS, BIMAX FAIED TO MAKE A HAZAREDOUS WASTE DETERMINATION FOR SPENT AEROSOL CANS, FAILED TO OBTAIN THE REQUIRED CERTIFICATION FOR A NEW HAZARDOUS WASTE TANK SYSTEM, FAILED TO MAINTAIN PROPER RECORDS PROVING NAMES AND DETAILED JOB DESCRIPTIONS OF FACILITY PERSONNEL ASSIGNED HAZARDOUS WASTE MANAGEMENT DUTIES, FAILED TO MARK AIR EMISSIONS EQUIPMENT SUBJECT TO RCRA SBPART BB, FAILED TO COMPLY WITH MONITORING/RECORDKEEPING FOR PUMPS IN LIGHT LIQUID SERVICE, AND FAILED TO COMPLY WITH AIR EMISSIONS STANDARDS FOR VALVES IN LIGHT LIQUID SERVICE. UNDER THE CAFO, BIMAX HAS AGREED TO FULLY COMPLY WITH HAZARDOUS WASTE MANAGEMENT REQUIREMENTS, PA A PENALTY AND PERFORM A SUPPLEMENTAL ENVIRONMENTAL PROJECT ( SEP ). THE SEP IS THE INSTALLATION AND OPERATION OF A THERMAL OXIDIZER TO ELIMINATE 9