On April 26, 2019, EPA filed a Consent Agreement and Final Order (CAFO) to resolve
allegations that Reviva Corporation failed to comply with Minnesota Hazardous Waste Management
Program conditions to maintain its RCRA permit exempt status, in violation of the Minnesota RCRA Program, 40 C.F.R. Part 265, and Section 3005(a) of RCRA, 42 U.S.C. section 6925(a). The conditions and requirements included failure to: date and label containers of hazardous waste, provide annual hazardous waste management training and maintain associated, have a written hazardous waste tank assessment for two of its hazardous waste tanks, close hazardous waste containers, accurately and completely list and describe hazardous waste management employee titles and duties, describe emergency equipment capabilities, properly label used oil containers, close used lamp containers, and the storage of used lamps for over 500 days. The Order required Reviva to comply with the Minnesota Program conditions to maintain its RCRA permit exempt status, or to obtain a RCRA Permit to store treat and dispose of hazardous waste, as provided by RCRA and the Minnesota Program, pay a civil penalty of $7,463.00, and expend at least $535,000.00 over five years on an Supplemental Environmental Project wastewater treatment system to reduce its hazardous wastewater from 5000 to zero gallons per month.