EPA subsequently issued CUNY a Complaint alleging the following violations of Subtitle C of RCRA and its implementing regulations, which include: Failure to make hazardous waste determinations for multiple waste streams in violation of 6 NYCRR § 372.2(a)(2) Failure to maintain or operate its Facility in a manner minimizing the possibility of a fire, explosion or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment in violation of 6 NYCRR 373-3.3(b) The CAFO states the Findings of Fact and Conclusions of Law are not intended, nor are they to be construed, as CUNY either admitting or denying such Findings and Conclusions. The CAFO assesses a civil penalty of $44,000.