On November 1, 2018, the EPA selected the Respondent for a compliance evaluation inspection under Subtitle C of the Resource Conservation and Recovery Act (RCRA) because at that time it was listed as a small-quantity generator (SQG) of hazardous waste in RCRAInfo that had not been inspected since 2009. The inspection was conducted on November 1, 2018. Findings include: On or about February 2017, 75,000 to 80,000 pounds of organic solvent-based inks (propanol/propyl acetate) in storage at the facility had become hazardous waste due to a switch to aqueous solvents to meet State VOC limits which made the facility a LQG. On November 13, 2018, Crystal Clean removed the remaining 11,570 pounds of waste ink from the facility, more than 90 days after the waste was generated as allowed for LQGs of hazardous waste without a permit. Also, an LQG who ships any hazardous waste offsite to a treatment, storage or disposal facility (TSDF) located within the United States must submit annual reports on forms specified by the Commissioner of the New York State Department of Environmental Conservation (NYSDEC). This report must be submitted to the NYSDEC no later than March 1st 2018 (for the 2017 calendar year) and provide information for the preceding calendar year. The parties agreed that the only two remaining post-compliance requirements under the CA/FO for the Respondent are (1) to submit the 2017 Annual Report to NYSDEC and to pay the $30,000 penalty.