The United States Environmental Protection Agency ( EPA ), Region 9, and Oreq Corporation ( Respondent ) agree to settle this matter and consent to the entry of this Consent Agreement ( CAFO ), which simultaneously commences and concludes this matter in accordance with 40 C.F.R. Sections 22.13 and 22.18. This is a civil administrative penalty assessment proceeding 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 15(3 (B) of TSCA, 15 U.S.C. Section 2614(3)(B), and federal regulations promulgated to implement Section 8(a) of TSCA, 15 U.S.C. Section 2607(a), at 40 C.F.R. Part 711. Respondent agrees to the assessment of a penalty in the amount of $23,453 as final settlement of the civil claims against Respondent arising under the TSCA as alleged in Section III of this CAFO. In executing this CAFO, Respondent certifies that it is now fully in compliance with the 40 C.F.R. Part 711.