From October 28, 2022, to November 30, 2023, EPA conducted a RCRA record review of the Facility's activities as a generator of hazardous waste. Based on its review, EPA determined Respondent generated hazardous waste streams in quantities that exceeded the threshold amount of kilograms of non-acute hazardous waste in a month, corresponding to Small Quantity Generator status under 30 T.A.C., Chapter 335, Subchapter C [40 C.F.R. Part 262].