On June 21, 2024, EPA Region III entered into a Consent Agreement and Final Order with PPC LUBRICANTS, LLC ( Respondent ) alleging violations of EPCRA and its implementing regulations. Respondent owned and operated a manufacturing plant which produces, distributes and repackages various lubricants for the automotive industry and for commercial and industrial equipment. EPA conducted a Compliance Evaluation Inspection ( CEI ) of the operations and activities of the Respondent at the Facility to determine the Facility's compliance status with the Toxics Release Inventory ( TRI ) reporting requirements under Section 313 of EPCRA and the regulations codified at 40 C.F.R. Part 372. EPA's records indicate that, at the time of the CEI, the Facility timely submitted toxic chemical release reports, Forms A, for the toxic chemical ethylene glycol, and for the toxic chemical category zinc compounds, for only calendar year 2021. However, evidence collected during the CEI revealed that the Facility had failed to submit its required TRI reports for ethylene glycol and zinc compounds for 2019 and 2020 by the July 1, 2020, and July 1, 2021, reporting deadlines, respectively. The failure to timely report for two (2) chemicals for two (2) years constitutes four (4) potential violations of Section 313(a) of EPCRA, 42 U.S.C. 11023(a) and 40 C.F.R. 372.30. On November 29, 2023, the EPA issued a Notice of Potential Violation and Opportunity to Confer ( NOPVOC') to Respondent addressing these pote