On July 25, 2022, EPA Region 6 issued a Consent Agreement and Final Order ( CAFO ) under its authority pursuant to the Resource Conservation and Recovery Act ( RCRA ) to Lanxess Corporation, located in El Dorado, AR. The CAFO was issued in response to violations of:
i. Failure to Meet the Requirements of Personnel Training.
The CAFO requires Lanxess to
A. Respondent shall certify that it has assessed all its solid waste streams at the Facility to determine the accurate waste codes and has developed and implemented standard operating procedures (SOPs) to ensure that Respondent is operating the Facility 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 its manifests; (e) meeting the requirements of the land disposal requirements; and (f) meeting the personnel training requirements of 40 C.F.R. ? 264.16.
B. Respondent shall certify that it has accurately and adequately complied with its RCRA Section 3010 notification for the Facility; and
C. Respondent shall provide, with its certification, a copy of Respondent's SOPs as described in subparagraph A above.
Lanxess must respond to EPA Region 6 within 120 days of the CAFO filing date.