EPA discovered RCRA violations during inspections in April 2008 and May 2010. EPA and Chicago Extruded Metals Company began negotiations in July 2011. The final agreement included implementation of a waste minimization Supplemental Environmental Project (SEP). The SEP would eliminate nearly all wastewater discharge from the facility and would result in a 60% reduction in the amount of hazardous wastewater treatment sludge generated. The final CAFO includes a SEP in the amount of $361,000 and the payment of a civil penalty of $80,714. Based on 2009 base year figures, the SEP will reduce the amount of wastewater treatment sludge generated each year by as much as 22,000 pounds. Based upon the average facility wastewater discharge for 2009-2010, the SEP will result in nearly 6,000,000 gallons less wastewater discharged per year.