This Expedited Settlement Agreement ( ESA ) is being entered into by the United States Environmental Agency ( EPA ), Region IX, by its duly delegated official, Amy Miller, Director, Enforcement and Compliance Assurance Division, and Bayer HealthCare, LLC ( Respondent ) pursuant to Section 113(a)(3) and (d) of the Clean Air Act (the Act ), 42 U.S.C Section 7413(a)(3) and (d), and by 40 C.F.R. Section 22.13(b). EPA has obtained the concurrence of the U.S. Department of Justice, pursuant to Section 113(d)(1) of the Act, 2 U.S.C. Section 7413(d)(1), to pursue this administrative enforcement action.