June 24, 2016, EPA issued a Consent Agreement and Final Order (CAFO) to TLMI to resolve RCRA violations. The violations were discovered during the period of October 2015 through November 2015 when EPA conducted an investigation and record review of TLMI?s performance as a hazardous waste generator. EPA discovered that TLMI, from 2011 to 2015, generated and offered for transport and disposal hazardous waste without obtaining an EPA ID number, had not made any notification to the state of Texas, failed to preform hazardous waste determinations, failed to comply with land disposal restrictions and failed to meet the generator requirements for training, contingency, and emergency preparedness while shipping waste that exceeded the threshold amount of 100 kg of hazardous waste per month which qualifies TLMI as a small quantity generator. During this period, TLMI was not registered as a small quantity generator, violating the requirement to provide adequate subsequent notification under RCRA ? 3010(a), 42 U.S.C. ? 6930(a). During this period, TLMI was operating as a small quantity generator without obtaining an EPA ID number under 40 CFR 262.13. During this period TLMI failed to meet the requirements of a small quantity generator 40 CFR 262 parts 262.32(d)(5)(i), 262.32(d)(5)(iii), 262.34(d)(5)(iv). During this period, TLMI failed to make adequate waste determinations 40 CFR 262.11. Lastly during this period, TLMI failed to comply with land disposal restrictions under 40 CFR