On February 1st, 2019 , EPA Region 6 issued a Consent Agreement and Final Order CAFO under its authority pursuant to RCRA to American plating company of Texas LTD located in Austin, Texas. The CAFO was issued in response to violations of RCRA hazardous waste generator requirements including: I)Failure to file initial or subsequent 3010 Notification and Failure to obtain an EPA ID number. II)Failure to meet the requirement of a LQG. III)Failure to submit the Biennial Report. The compliance order section of the CAFO requires American Plating Company of Texas LTD to pay a civil penalty of 18354 and to respond to EPA within 30 calendar days of the effective date of the CAFO with the following certifications:
a. Respondent shall certify that it has assessed all its solid waste streams to determine the accurate waste codes and has developed and implemented Standard Operating Procedures (SOP) to ensure that Respondent is operating in compliance with RCRA and the regulations promulgated thereunder, including, but not limited to, procedures for: (i) managing hazardous wastes; and (ii) reporting, transporting, and disposing of hazardous waste; b. Respondent shall certify that it has accurately and adequately complied with its RCRA Section 3010 Notification requirements; c. Respondent shall obtain an EPA ID number; and d. Respondent shall certify that it has adequate contingency plans, Emergency Procedures and proper training for managing, reporting, transporting and disposing