On August 22, 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 TDC, LLC in Westlake, Texas. Data from a Texas treatment, storage, and disposal facility indicated discrepancies between TDC?s designated status as conditionally exempt and actual shipments as a large quantity generator (LQG) 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 December 2016. The CAFO addresses violations including failure to provide notification of hazardous waste activities, failure to operate within the stated generator status and meet the attendant requirements of a large quantity generator. The CAFO also requires TDC to certify and document compliance with the applicable hazardous waste generator requirements and imposes a penalty of $33,990.