Document 4Qznpr9R3d5qvZ7zYY1DY8YKQ

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION6 1445 ROSS AVENUE, SUITE 1200 DALLAS, TX 75202-2733 March 16, 2016 CERTIFIED MAIL-RETURN RECEIPT REQUESTED: 7015 1520 0003 3989 5138 Coy Reece Environmental Manager Texas Couplings 1835 Old Holzwarth Road Spring, Texas 77388 RE: Potential RCRA Violations and Opportunity for Settlement Dear Mr. Reece, The United States Environmental Protection Agency, Region 6 ("EPA"), through its investigation and records review, has reason to believe that Texas Couplings, located at 1835 Old Holzwarth Road, Spring, TX 77388, has violated the Resource Conservation and Recovery Act ("RCRA"), and the regulations promulgated thereunder. Current Areas of Concern As a generator of hazardous waste, Texas Couplings is subject to Subtitle C of RCRA Hazardous Waste Management, 42 U.S.C. 6920 et seq. and the regulations set forth in 30 TEX. ADMIN. CODE Subchapters C and/or F, which implement regulations from 40 C.F.R. Parts 262 and/or 270. Upon further investigation, EPA may also determine that Texas Couplings is also subject to other RCRA regulations. ~ased on EPA's current investigation and records review, Texas Couplings has been generating hazardous waste and offering its hazardous waste for transportation and/or directly for treatment from at least 2011 through 2013. Further, EPA has determined that the amount of Texas Coupling's hazardous waste generation likely triggers the large quantity generator requirements of RCRA. At a minimum, EPA has identified the following preliminary violations of RCRA by Texas Coupling: i. Failurefo comply with RCRA notification requirements, in violation of Section 3010(a) of RCRA, 42 U.S.C. 6930(a). EPA is prepared to meet and discuss this and other potential violations with Texas Couplings, with the aim of resolving this matter through an expedited settlement process. An Option for Resolution If Texas Coupling is interested in resolving this matter through an expedited settlement process, please call, write, or email the attorney assigned to this matter, Matthew Trawick, by March 31, 2016. Thereafter, Mr. Trawick will make arrangements to meet with Texas Coupling via conference call. During this initial meeting, EPA will request documents related to hazardous waste management and generation. Texas Couplings will then have the opportunity to address any potential violations and present any evidence that contravenes EPA's findings. After our initial conference and information exchange, EPA will provide Texas Coupling with a draft Consent Agreement and Final Order ("CAFO"), which sets forth the nature and facts supporting any violations. The primary goal of this expedited settlement is to bring Texas Coupling into timely compliance with applicable environmental laws and regulations, and not to maximize penalty. Timetable for Resolution EPA estimates that if Texas Coupling avails itself of the settlement process that EPA is now offering, the parties could have an agreed CAFO by July 2016. However, it should be noted that if Texas Coupling decides not to accept thi~ expedited settlement process, the EPA will exercise its other options for ensuring Texas Coupling's timely compliance. 2