On September 30, 2019, EPA Region III, the Department of Justice ( DOJ ), the State of Maryland ( State ), and the Central Chemical Site Respondent Group ( Respondent Group ) entered into an Agreement on Stipulated Penalties ( Agreement ) for alleged violations of a 2015 RD/RA Consent Decree ( CD ) and a 1997 Administrative Order on Consent for Remedial Investigation/Feasibility Study ( AOC ), involving cleanup of the Central Chemical Superfund Site in Hagerstown, Maryland ( Site ). Under the terms of the Agreement, the Respondent Group will pay a total of $676,000 in stipulated penalties for violations of the CD and AOC. DOJ issued the Respondent Group a demand letter on April 29, 2019, alleging violations of the CD and AOC. The CD violations included: (i) submission of monthly progress reports that did not discuss the dioxin sampling results; (ii) failure to timely respond to EPA's request for documentation relating to the inclusion of dioxin in the discharge permit for the Site; and (iii) failure to submit a work plan to EPA and the State for review and approval in advance of the April 2018 dioxin sampling. The AOC violations included: (i) failure to timely notify EPA of changed circumstances at the Site; (ii) failure to provide information relating to dioxin sampling at the Remedial Investigation meeting; (iii) submission of a Remedial Investigation report that did not discuss the dioxin sampling results; and (iv) submission of a Risk Assessment that did not analyze the d