MARCH 13, 2023 - CONSENT AGREEMENT
On July 9, 2021, and November 11, 2021, Respondent submitted certain records to the EPA
regarding Respondent's compliance with TSCA Sections 4, 5, 8, 12 and 13, including import, manufacture, and export records.
On June I 0, 2022, after reviewing the records submitted by Respondent, the EPA issued Respondent an Opportunity to Show Cause letter identifying potential violations of TSCA Section 8 pertaining to CDR reporting and TSCA Section 12 pertaining to export notice submission. On July I, 2022, Respondent provided additional information to the EPA in response to the Show Cause.
Over-Reporting of Chemical A [CBI deleted) in the 2020 CDR Report
Pursuant to 40 C.F.R. ? 71 l. l 5(b)(3)(iii), for the principal reporting year only, the total annual domestically manufactured volume (not including imported volume) and the total annual imported volume of chemicals subject to reporting must be separately reported. These amounts must be reported to two significant figures of accuracy. Chemical A was included in Respondent's 2020 CDR Report that was submitted to the EPA during the reporting period. A comparison between the 2020 CDR Report and the 2019 production records indicates that Chemical A was over-reported (not reported to two significant figures of accuracy) in its CDR Report.
Export of Chemical B [CBI deleted)
Based on a review of the Facility's 2017 - 2019 export records, Respondent exported 67 shipments of Product X [CBI