3/26/2026 - CONSENT AGREEMENT AND FINAL ORDER ISSUED ASSESSING A PENALTY OF $62,500.00 DUE WITHIN 30 DAYS AFTER THE EFFECTIVE DATE OF THIS CAFO.
ALLEGED VIOLATIONS:
ON MARCH 19, 2025, THE EPA ISSUED A NOTICE OF INSPECTION NOTIFYING RESPONDENT THAT THE EPA WOULD BE CONDUCTING AN INSPECTION AT RESPONDENT'S FACILITY PURSUANT TO SECTION LL(A) OF TSCA, 15 U.S.C. ? 2610(A), TO EVALUATE RESPONDENT'S COMPLIANCE WITH TSCA. IN RESPONSE TO THE NOTICE OF INSPECTION, ON APRIL 7, 2025, RESPONDENT SUBMITTED CERTAIN RECORDS TO THE EPA PERTAINING TO ITS MANUFACTURE, PROCESSING, EXPORTATION, AND IMPORTATION OF CHEMICALS. ON MARCH 26, 2025, THE EPA CONDUCTED THE INSPECTION AT RESPONDENT'S FACILITY. ON JULY 15, 2025, AFTER REVIEWING RECORDS SUBMITTED BY RESPONDENT ON APRIL 7, 2025, THE EPA ISSUED RESPONDENT AN OPPORTUNITY TO SHOW CAUSE LETTER ALLEGING THAT RESPONDENT POTENTIALLY VIOLATED SECTIONS 8, 12, AND 15 OF TSCA, 15 U.S.C. ?? 2607, 2611, AND 2614, BY FAILING TO COMPLY WITH THE CDR REQUIREMENTS APPLICABLE TO IMPORTERS, AND THE TSCA SECTION 12(B) REQUIREMENTS APPLICABLE TO EXPORTERS, FOUND IN 40 C.F.R. PARTS 711 AND 707, RESPECTIVELY. ON JULY 18, 2025, RESPONDENT PROVIDED ADDITIONAL INFORMATION TO THE EPA IN RESPONSE TO THE OPPORTUNITY TO SHOW CAUSE LETTER.
BASED ON THE EPA'S INVESTIGATION, INCLUDING A REVIEW OF RESPONDENT'S RECORDS, THE EPA ALLEGES THAT RESPONDENT FAILED TO:
A. SUBMIT A 2024 CDR REPORT FOR CHEMICALS A AND B DURING THE 2024 CDR SUBMISSION PERIOD WHICH ENDED ON NOVE