On August 9, 2017, EPA Region 6 issued a Consent Agreement and Final Order (CAFO) under its authority pursuant to the Resource Conservation and Recovery Act (RCRA) to Professional Compounding Company of America (PCCA) located in Houston, Texas. Data from a Texas treatment, storage, and disposal facility indicated discrepancies between PCCA?s designated status as conditionally exempt and actual shipments as a small quantity generator (SQG) subject to hazardous waste generator requirements. The State participated in training on the data mining methodology. The Region notified the State of the potential violations and our intention to investigate and pursue enforcement before notifying the company by letter in November 2015. The CAFO addresses violations including failure to provide notification of hazardous waste activities, failure to operate within the stated generator status, failure to complete hazardous waste manifests and failure to maintain records of hazardous waste determinations. It requires PCCA to certify and document compliance with the applicable hazardous waste generator requirements and imposes a penalty of $94,000.