APRIL 6, 2026 - CONSENT AGREMENT
On October 31, 2022, the EPA sent Respondent a Notice of Inspection notifying Respondent that the EPA would be conducting an inspection of Respondent's Facility pursuant to Section 11(a) of TSCA, 15 U.S.C. ? 2610(a), to evaluate Respondent's compliance with TSCA. In response to the Notice of Inspection, on December 8, 2022, Respondent submitted certain records to the EPA pertaining to its
manufacture, processing, exportation, and importation of chemicals.
On December 8, 2022, authorized agents of the EPA conducted the inspection at Respondent's Facility. On request from the EPA, Respondent submitted additional records related to the inspection to the EPA on January 19 and February 1, 2023.
On April 24, 2024, after reviewing the records submitted by Respondent, the EPA issued Respondent an Opportunity to Show Cause letter alleging that Respondent had potentially violated Sections 8 and 12 of TSCA, 15 U.S.C. ?? 2607 and 2611, by failing to comply with the CDR and TSCA Section 12(b) export requirements found in 40 C.F.R. Parts 711 and 707, respectively, among other potential
violations. On June 12, 2024, April 7, 2025, and August 21, 2025, Respondent provided additional information to the EPA in response to the Opportunity to Show Cause letter.
Based on a review of the records submitted by Respondent, including import records from 2016-2019, the EPA determined that Respondent imported a reportable quantity (greater than 25,000 p