This is a consolidated action pursuant to our Consolidated Rules of Practice (40 C.F.R. ?22.18(b)(2) and (3)), which provide that a proceeding may be simultaneously commenced and concluded by the issuance of a Consent Agreement and Final Order when the parties agree to settle one or more causes of action before the filing of an Administrative Complaint.
A review of the Toxic Release Inventory Envirofacts Database indicated that Respondent voluntarily submitted the following late Toxic Release Inventory Form R reports:
1) The Form R reports for for epichlorohydrin, dimethylamine, o-xylene, and methanol were submitted to the EPA for the 1997 calendar year on July 1, 2000. Each Form R report was greater than one year late
2) The Form R reports for epichlorohydrin, dimethylamine, methyl isobutyl ketone, o-xylene, and methanol were submitted to the EPA for the 1998 calendar year on July 1, 2000. Each Form R report was greater than one year late.
On October 22, 2002, a letter addressing the above late reporting violations was sent to the company in an effort to gain more insight into the circumstances concerning the above violations. An EPCRA Section 313 inspection was also conducted at the facility on October 24, 2002 in conjunction with a TSCA Sections 5, 8 and PCB inspection. By letter dated December 11, 2002, Mr. Warner Jarnagin, Manufacturing Manager provided the requested information for CVC Specialty Chemcials, Inc. Based on this information, it was determi