This is a civil administrative penalty action initiated against Respondent pursuant to Section 16(a) of the Toxic Substances Control Act ( TSCA ), 15 U.S.C. section 2615(a), for violation of Section 409 of TSCA, 15 U.S.C. Sections 2682 and 2686, and their implementing regulations promulgated at 40 C.F.R. Part 745, Subpart E. Respondent agrees to the assessment of a penalty in the amount of $25,000 as final settlement of the civil claims against Respondent arising under TSCA. In executing this CAFO, Respondent certifies that it is now in compliance with the federal regulations promulgated at 40 C.F.R. Part 745, Subpart E.