Rhodia Inc. (Rhodia) acquired the former McIntyre Group facility located at 24601 Governors Highway, University Park, Illinois on February 27, 2009. On October 30, 2009, Rhodia requested an audit agreement and submitted its plan to conduct comprehensive multimedia compliance assessments of the McIntyre facility. In the course of its review of its multimedia compliance assessments, Rhodia identified potential violations of EPCRA, CAA, CWA, RCRA, and TSCA.
Because RhodiaÂs disclosure came in under the ÂInterim Approach to Applying the Audit Policy to New Owners, 73 Fed. Reg. 44,991 (Aug. 1, 2008) (Interim Approach), and it met the Policy conditions, we applied the penalty mitigation of the Interim Approach. Becasue the Economic Beneifit on Noncompliance was deemmed insignificant, no penalties for economic benefit were assessed.