On April 25, 2022, EPA Region 6 issued an ACOC under its authority pursuant to the Resource Conservation and Recovery Act to American Airlines Flight Academy, located in Fort Worth, TX. The ACOC was issued in response to violations of: 1) Failure to file initial or subsequent notification 2) Failure to operate under correct generator status.. The ACOC requires American Airlines Flight Academy to:
1. Pursuant to Section 3008(a) of RCRA, 42 U.S.C. ? 6928(a), Respondent is hereby ordered to take the following actions, and within thirty (30) calendar days of the effective date of the settlement agreement, Respondent shall provide in writing the following:
A. Respondent shall certify that it has assessed all of its solid waste streams at the Facility to determine the accurate waste codes and has developed and implemented its Standard Operating Procedures (?SOP?) to ensure that American Airlines Flight Academy is operating in compliance with RCRA and the regulations promulgated thereunder, including, but not limited to, procedures for: (a) making hazardous waste determinations; (b) managing hazardous wastes; (c) reporting, transporting, and disposing of hazardous waste; (d) preparing the manifests; and (e) meeting the requirements of the land disposal restrictions;
B. Respondent shall certify that it has accurately and adequately complied with its RCRA Section 3010 Notification; and
C. Respondent shall provide, with its certification, a copy of Respondent?s SOPs as described