On August 13, 2020, EPA informed ZionSolutions, LLC, of alleged potential violations of the RCRA. Specifically, EPA informed ZionSolutions, LLC, that based on a review of data, it appeared that ZionSolutions, LLC, had improperly identified itself as a small quantity generator of hazardous waste. During 2017, ZionSolutions, LLC, generated hazardous waste in quantities that qualified ZionSolutions, LLC, for large quantity generator status. Thus, EPA identified the following potential violations: failure to submit sufficient initial notification and/or subsequent notification of the change in the type of RCRA hazardous waste activity in violation of Section 3010(a) of RCRA, 42 U.S.C. ? 6930(a) (EPA Form 8700-12); and failure to file one annual report in violation of Ill. Admin. Code tit. 35 ? 722.141 [40 C.F.R. ? 262.41]. EPA offered and ZionSolutions, LLC, agreed to resolve the violations through a streamlined CAFO settlement process.