On 15 November, 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 Custom Building Products, LLC, located in Grand Prairie, TX. The CAFO was issued in response to violations of:
i. Notification Requirements;
ii. Failure to meet the standards of a Small Quantity Generator; and
iii. Failure to make adequate hazardous waste determinations.
The CAFO requires Custom Building Products, LLC to:
A) Respondent shall certify that it has assessed all its solid waste streams at the Custom Building Products, LLC Facility to determine the accurate waste codes and has developed and implemented standard operating procedures ( SOPs ) to ensure that Respondent is operating the Custom Building Products, LLC 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; and (e) meeting the requirements of the land disposal requirements;
B) Respondent shall certify that it has accurately and adequately complied with its RCRA Section 3010 notification for the Custom Building Products, LLC Facility and within the prescribed time period; and
C) Respondent shall provide, with its certification, a copy of Respondent's SOPs as described in subparagraph A above.