During the period from August 15, 2019 to October 23, 2019, EPA conducted a RCRA record review of the Facility's activities as a generator of hazardous waste including a review of the information voluntarily provided to EPA by Respondent. During the Investigation, EPA discovered that Respondent, at a minimum, generated and offered for transport and treatment, hazardous wastes. From the Investigation, EPA determined that Respondent generated the hazardous waste streams identified 14 in quantities that exceeded the threshold amount of 1000kg per month. Respondent did not file with EPA or the authorized state (Texas), an adequate and timely notification of its hazardous waste activities at the Facility during the period from 2017 ? 2019. During portions of 2017-2019, the Facility exceeded their declared SQG status and operated in some instances as a Large Quantity Generator in violation of one or more of the requirements for small quantity generators.