8/28/18 - CONSENT AGREEMENT AND FINAL ORDER ISSUED ASSESSING A PENALTY OF $21,675 DUE WITHIN 30 DAYS. RESPONDENT ALSO AGREES TO COMPLETE A SEP.
ALLEGATIONS:
ON JAN 5, 2017, RESPONDENT SUBMITTED CERTAIN RECORDS TO EPA REGARDING RESPONDENT'S COMPLIANCE WITH TSCA, INCLUDING MANUFACTURING, IMPORT, AND EXPORT RECORDS.
PURSUANT TO 40 CFR 711.8(a)(2), ANY PERSON WHO MANUFACTURED (INCLUDING IMPORTED) FOR COMMERCIAL PURPOSES 25,000 OR MORE OF A CHEMICAL SUBSTANCE DESCRIBED IN 40 CFR 711.5 AT ANY SINGLE SITE OWNED OR CONTROLLED BY THAT PERSON, IN ANY OF THE CALENDAR YEARS 2012, 2013, 2014, 2015 ARE SUBJECT TO THE CHEMICAL DATA REPORTING (CDR) REQUIREMENTS IN 40 CFR PART 711 FOR THE 2016 SUBMISSION PERIOD. PURSUANT TO 40 CFR 711.20, THE 2016 SUBMISSION PERIOD RAN FROM JUNE 1, 2016 UNTIL OCT 31, 2016, AND 2016 CDR REPORTS WERE REQUIRED TO HAVE BEEN SUBMITTED TO EPA DURING THAT PERIOD OF TIME.
PURSUANT TO 40 CFR 711.5 ANY CHEMICAL SUBSTANCE THAT IS IN THE TSCA MASTER INVENTORY FILE AT THE BEGINNING OF A SUBMISSION PERIOD DESCRIBED IN 40 CFR 711.20 MUST BE REPORTED PURSUANT TO THE CDR REQUIREMENTS UNDER TSCA SECTION 8(a) OF TSCA AND 40 CFR PART 711, UNLESS THE CHEMICAL SUBSTANCE IS SPECIFICALLY EXCLUDED BY 40 CFR 711.6.
A REVIEW OF RESPONDENT'S 2015 PRODUCTION RECORDS REVEALED THAT RESPONDENT MANUFACTURED (INCLUDING IMPORTED) A REPORTABLE QUANTITY (>25,000 POUNDS) OF 4 CHEMICAL SUBSTANCES, CHEMICALS B, C, D, AND E FOR COMMERCIAL PURPOSES AT ITS MOBILE SITE.
ALL 4 CHEMICA