During the period of October 2015 through November 2015, EPA conducted an investigation and record review of Respondent?s performance as a hazardous waste generator. EPA discovered that Lone Star Fasteners, at a minimum, generated and offered for transport and treatment hazardous waste during 2013 - 2014 that exceeded the threshold amount of 1,000 kg of hazardous waste per month which would qualify Lone Star Fasteners for a large quantity generator status. During that period, Lone Star was registered as a small quantity generator. On March 15, 2016, EPA issued a Consent Agreement and Final Order to LoneStar Fastener to resolve the RCRA violations.