On September 29, 2020, EPA Region 5 and Cul-Mac Industries, Inc. (Cul-Mac) of Wayne, Michigan, entered into a Resource Conservation and Recovery Act (RCRA) Section 3008(a) Consent Agreement and Final Order (CAFO) resolving violations relating to failure to provide notification of hazardous waste activity and failure to file a biennial report. The CAFO requires Cul-Mac to pay a standard, pre-approved, penalty of $11,471 and to submit the required biennial report and a revised notification. Cul-Mac operates as a manufacturer of household and industrial automotive chemicals. On August 19, 2020, EPA informed Cul-Mac of alleged potential violations of the RCRA. Specifically, EPA informed Cul-Mac that based on a review of data, it appeared that Cul-Mac had improperly identified itself as a small quantity generator of hazardous waste. During 2017, Cul-Mac generated hazardous waste in quantities that qualified it 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 870012); and failure to file annual/biennial reports in violation of Michigan?s equivalent to 40 C.F.R. ? 262.41. EPA offered and Cul-Mac agreed to resolve the violations through a streamlined CAFO settlement process. EPA Region 5 identified the violations through its