This is a civil administrative enforcement action instituted pursuant to Section 3008(a)(1) of the Resource Conservation and Recovery Act (RCRA), as amended, 42 U.S.C. Section 6928(a)(1), and the Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties and the Revocation/Termination of Suspension of Permits, as codified at 40 Code of Federal Regulations (C.F.R.) Part 22 (Consolidated Rules). Respondents agree to pay a civil penalty of $230,000 for the violations. In executing this CAFO, Respondents certify under penalty of law to EPA that they have fully complied with RCRA and its implementing regulations that formed the basis for the violations.