AUGUST 16, 2024 - CONSENT AGREEMENT
On June 8, 2023, the EPA sent Respondent a Notice of Inspection pursuant to Section 11(a) of TSCA, 15 U.S.C. 2610(a), notifying Respondent that the EPA would be conducting an inspection of Respondent's Facility to determine its compliance with TSCA. Pursuant to a request in the Notice, Respondent submitted certain records to the EPA prior to the inspection pertaining to its manufacture and importation of chemicals. On July 26, 2023, inspectors from the EPA Region 4 conducted a TSCA inspection at Respondent's Facility pursuant to Section ll(a) of TSCA, 15 U.S.C. ? 2610(a).
Based on a review of the records submitted by Respondent, the EPA issued Respondent an
Opportunity to Show Cause letter on May 29, 2024, identifying potential violations of TSCA Section
8 pertaining to 2020 CDR reporting and TSCA Section 12 export requirements. On June 3, 2024,
Respondent provided additional information to the EPA in response to the Opportunity to Show
Cause letter. A show cause meeting was conducted with Respondent on June 20, 2024, to discuss
potential violations.
On November 17, 2020, Respondent timely submitted its first 2020 CDR Report for twenty-five (25) chemicals (including Chemicals E and F) which Respondent had manufactured and imported for commercial purposes in quantities greater than 25,000 pounds during at least one of the years in the period 2016-2019. The report was required to be submitted by no later than the end of the 2020