On June 25, 2019, the United Stated Environmental Protection Agency (?EPA?) Region 6 enforcement team filed a Consent Agreement and Final Order (?CAFO?) against Ascend to resolve RCRA and CWA violations for an amount of $976,707.00 (The total civil penalty of $976,707.00 is divided between RCRA and CWA as follows: RCRA equaling $909,365.00 and CWA equaling $67,342.00). The CAFO also includes a comprehensive compliance order. Ascend is located in Alvin, Texas and operates on 2,500 acre integrated chemical manufacturing complex originally developed by Monsanto, which commenced operations in 1962. The facility was acquired by Ascend in 2009, and currently houses at least five owners of different chemical units inside a single fence line under one EPA identification number for RCRA, one CWA permit, and individual reporting for EPCRA. Pursuant to RCRA and the regulations promulgated thereunder, Ascend is a large quantity generator of hazardous waste and operates also as a hazardous waste treatment, storage, disposal facility. Ascend is the largest generator of hazardous waste in the US. The EPA R6 and HQs inspected Ascend in 2015 and again in September 2017 that identified violations under RCRA and CWA. The RCRA violations include: storage without a permit; operating auxiliary equipment without secondary containment; violation of Ascend?s RCRA permit; management of hazardous waste in sumps without meeting the applicable RCRA requirements; waste analysis plans that do not