On November 3, 2016, EPA Region 6 issued a Consent Agreement and Final Order (CAFO) under the Resource Conservation and Recovery Act (RCRA) to Ritz-Carlton located in New Orleans, Louisiana. The CAFO was issued in response to RCRA violations of: 1) failure to file with the EPA Administrator or the authorized State a notification of its hazardous waste activities in violation of Section 3010(a) of RCRA, 42 U.S.C. ? 6930(a), and 2) exceeding the limits for generation of hazardous waste, and therefore, at minimum, operated as a small quantity generator (?SQG?) in violation of the regulations set forth at 40 C.F.R. Part 262. The CAFO requires Ritz-Carlton to pay a penalty of $22,660.00 and implement a Supplemental Environmental Project (SEP) that will reduce the quantity and toxicity of pollutants from the on-site dry cleaning operations, through installation of a new system using a less toxic dry cleaning fluid formulation. Implementation of the SEP should be completed by December 31, 2016 with certification of completion by January 2017.