On April 2, 2019, EPA Region 6 issued a Consent Agreement Final Order (CAFO) under its authority pursuant to the Resource Conservation & Recovery Act (RCRA) to Western Refining Southwest-Gallup Refinery located in Jamestown, New Mexico. The CAFO was issued in response to violations of: 1) failing to make Hazardous Waste Determinations; 2) sending Hazardous Waste to a facility that does not have a RCRA Identification Number and is not permitted to treat, store, or dispose hazardous waste; 3) failing to use hazardous waste Manifests for shipping hazardous wastes. The CAFO requires the Western Refining Southwest-Gallup Refinery to: 1) within 45 days, certify that it has developed and implemented a standard operating procedure (?SOP?) for conducting hazardous waste determinations on all solid wastes generated at the facility. The SOP must be compliant with 40 C.F.R. ? 261 and 40 C.F.R. ? 268. For a period of one year from the effective date of the CAFO the environmental health and safety manager of the facility must review and sign-off on every solid and hazardous waste determination made at the facility; 2) within 6 months, certify that it has developed and is implementing a training program, for both current employees and new hires, compliant with 40 C.F.R. ? 265.16; 3) within 45 days, certify that it has established a system of management review of solid and hazardous waste determinations at the facility. This management oversight system must be sufficient to provide adeq