AT THE FACILITY, RESPONDENT OPERATED AN AIRCRAFT PARTS CLEANING PROCESS FOR WHICH RESPONDENT WAS PERIODICALLY A SMALL QUANTITY GENERATOR OF HAZARDOUS WASTE AND ARRANGED FOR OFF-SITE SHIPMENT AND DISPOSAL OF HAZARDOUS WASTE RESULTING FROM THE PARTS CLEANING OPERATIONS. BASED IN PART ON THE INFORMATION DISCLOSED BY FORT COLLINS IN THEIR ASSESSMENT REPORT AND ON OTHER INFORMATION PROVIDED BY THE RESPONDENT TO EPA, RESPONDENT DID NOT FULLY COMPLY WITH THE SMALL QUANTITY GENERATOR REQUIREMENTS AND THE NON-COMPLIANCE OCCURRED DURING RESPONDENT'S OPERATIONS AT THE FACILITY. RESPONDENT AGREES TO PAY A CIVIL PENALTY OF $2,609.38 AND WILL PERFORM A SEP, FOR WHICH THE TOTAL EXPENDITURE SHALL NOT BE LESS THAN $13,160.