EPA Region 6 issued a Consent Agreement and Final Order under its authority pursuant to Resource Conservation and Recovery Act to Home Depot U.S.A, Inc 's 275 stores located in Region 6. The CAFO was issued in response to violations of: ? Failure to file subsequent Notification;
? Failure to Perform Land Disposal Determinations;
? Failure to Comply with the Manifest Requirements; and
? Failure of Personnel Training to Ensure Facilities Compliance.
The CAFO requires Home Depot U. S.A, Inc i. Within two hundred and forty (240) days of the effective date of the CAFO to develop (or revise existing) for EPA, Region 6?s review (but not approval) and for its subsequent implementation one or more written procedures (the ?Procedures?) that will collectively describe the implementation of a centralized process applicable to all the Facilities subject to the CAFO and will address (1) Hazardous waste determinations; (2) Section 3010 RCRA Notification submissions; (3) Employee training; (4) Record-Keeping; (5) Land Disposal Restrictions; (6) Management of hazardous waste while on site, to include contingency plans (for any facility that is a LQG) and emergency procedures; and (7) Manifesting requirements.
ii. Within 180 days of the effective date of the CAFO, will employ a third-party consultant who will audit at least 20% of the Facilities listed in Appendix I of this CAFO on an annual basis for two years, to include a representative number of Facilities from each Region 6