The United States Environmental Protection Agency, Region IX (EPA), and Valent U.S.A. LLC (Respondent) agree to settle this matter and consent to the entry of this Consent Agreement and Final Order (CAFO), which simultaneously commences and concludes this matter in accordance with 40 C.F.R. 22.13(b) and 22.18(b). Respondent agrees to the assessment of a penalty in the amount of $12,940 as final settlement of the civil claims against Respondent arising under the Act as alleged in Section 1.C of the CAFO. Respondent certifies that, to the best of its knowledge, it is currently in compliance with any and all FlFRA requirements that apply to its ongoing operations.