On March 25, 2019, EPA Region 6 issued an Administrative Compliance Order on Consent (ACOC) under its authority pursuant to the Resource Conservation and Recovery Act (RCRA) to ALX Industries, LLC (ALX), located in Pasadena, Texas. ALX serves as an industrial and hazardous waste management company. ALX is registered very small quantity generator (VSQG). ALX specializes in servicing the Non-destructive testing industry (NDT), disposing and recovering silver from spent materials used in the development and printing industrial x-ray film. ALX recovers silver from photographic chemical solutions such as developer and fixer. These spent chemicals contain characteristic levels of silver and has an economic value hence ALX?s service to recover the silver prior to disposal of these spent solutions. The ACOC was issued in response to a violation identified during an EPA inspection conducted in August 2018 where inadequate testing of spent chemical resulted in exceedances of RCRA characteristic levels. ALX failed to perform a hazardous waste determination on one or more of its waste streams violating 30 Tex. Admin. Code ? 335.62, [40 C.F.R. ? 262.11]. As part of the ACOC, ALX has agreed to return to and certify compliance within 60 days.