On September 30, 2009, U.S. EPA filed a Consent Agreement and Final Order (CAFO) against Usher Enterprises, Inc. (ÂUsherÂ), alleging that Usher violated Section 3005(a) of RCRA, 42 U.S.C. § 6925, at its facilities in Detroit, Michigan. The allegations included UsherÂs failure to comply with RCRA used oil generator, processor, and marketer requirements.