This Consent Agreement and Final Order ( CA/FO ), pursuant to 40 C.F.R. Sections 22.13 and 22.18, simultaneously commences and concludes this proceeding, wherein EPA alleges that Respondent violated Section 3008 of RCRA, 42 U.S.C. Section 6928, and state regulations adopted pursuant to the approved California hazardous waste management program. Respondent consents to the assessment of and agrees to pay a civil penalty of $49,706. Respondent certifies under penalty of law to EPA that it has fully complied with Section 3008 of RCRA, 42 U.S.C. Section 6928 and its implementing regulations that formed the basis for the violations.