On July 12, 2017, EPA informed American Cylinder of alleged potential violations of the RCRA. Specifically, EPA informed American Cylinder that American Cylinder had for several periods improperly identified itself as a small quantity generator of hazardous waste. During 2013 and 2015, American Cylinder generated hazardous waste in quantities that qualified American Cylinder for large quantity generator status. Thus, EPA identified the following potential violations: failure to comply with the large quantity generator conditions for a permit exemption at 35 IAC 722.134 [40 C.F.R. ? 262.34], and failure to file annual/biennial reports in violation of 35 IAC ? 722.141 [40 C.F.R. ? 262.41]. EPA offered, and American Cylinder agreed, to resolve the violations through a streamlined CAFO settlement process. The SEP consists of installation and operation of a pollution prevention project including the purchase and use of a new compressor system that reduces energy use.