MARCH 13, 2023 - CONSENT AGREEMENT
On January 27 and 28, 2021, an authorized agent of EPA Region 4 conducted a virtual inspection of Respondent's facility through a Microsoft Teams call with representatives of Respondent pursuant to Section 1 l(a) of TSCA, 15 U.S.C. ? 2610(a). On February 25 and June 7, 2021, in response to discussions during the virtual inspection, Respondent submitted certain records to the EPA regarding Respondent's compliance with TSCA, including import, manufacture, and export records.
On September 12, 2022, after reviewing the records submitted by Respondent, the EPA issued Respondent an Opportunity to Show Cause letter identifying potential violations of TSCA Section 8 pertaining to CDR reporting. On September 26, October 17, and November 9, 2022, Respondent provided additional information to the EPA in response to the Show Cause letter.
Chemical Data Reporting for Chemical E (CBI Deleted)
A review of Respondent's 2018 and 2019 import and manufacture records revealed that Respondent manufactured a reportable quantity (greater than 25,000 pounds) of Chemical E for commercial purposes in those years.
Chemical E was listed in the TSCA Master Inventory File at the beginning of a submission period described in 40 C.F.R. ? 711.20 and is not specifically exempted from some or all the CDR reporting requirements by 40 C.F.R. ? 711.6.
Pursuant to 40 C.F.R.?711.15, Respondent was required to submit a 2020 CDR Report to the EPA that included eac