3/26/2026 - CONSENT AGREEMENT AND FINAL ORDER ISSUED ASSESSING A PENALTY OF $56,100.00 DUE WITHIN 30 DAYS AFTER THE EFFECTIVE DATE OF THIS CAFO.
ALLEGED VIOLATIONS:
ON JUNE 25, 2025, RESPONDENT VOLUNTARILY SUBMITTED CERTAIN RECORDS TO THE EPA AT THE REQUEST OF THE EPA IN LIEU OF THE EPA CONDUCTING AN ON-SITE INSPECTION OF RESPONDENT'S FACILITY PURSUANT TO SECTION 11 OF TSCA, 15 U.S.C. ? 2610. ON SEPTEMBER 24, 2025, AFTER REVIEWING THE IMPORT RECORDS SUBMITTED BY RESPONDENT, THE EPA ISSUED RESPONDENT AN OPPORTUNITY TO SHOW CAUSE LETTER ALLEGING THAT RESPONDENT HAD POTENTIALLY VIOLATED SECTION 8 OF TSCA, 15 U.S.C. ? 2607, BY FAILING TO COMPLY WITH THE CDR REQUIREMENTS FOUND IN 40 C.F.R. PART 711. ON OCTOBER 2, 2025, RESPONDENT PROVIDED A RESPONSE TO THE OPPORTUNITY TO SHOW CAUSE LETTER ACCEPTING THE POTENTIAL VIOLATION.
BASED ON THE EPA'S INVESTIGATION, INCLUDING A REVIEW OF RESPONDENT'S RECORDS, INCLUDING IMPORT RECORDS FROM 2020-2023 AS SET FORTH IN THE CAFO, THE EPA ALLEGES THAT RESPONDENT FAILED TO SUBMIT A 2024 CDR REPORT FOR CHEMICALS A AND B DURING THE 2024 CDR SUBMISSION PERIOD WHICH ENDED ON NOVEMBER 22, 2024, IN VIOLATION OF 40 C.F.R. ?711.15, AND SECTIONS 8 AND 15 OF TSCA, 15 U.S.C. ?? 2607 AND 2614, AS SET FORTH IN SECTION IV OF THE CAFO.