Hanwha Cimarron LLC (Board decision, February 23, 2024)

In re Hanwha Cimarron LLC (EAB CAA Appeal No. 24-02C): HFC import settlement approved

Decision type

Board decision

Docket

CAA 24-02C

Decided

February 23, 2024

Outcome

Settled

Precedential status

Citable Board precedent

Checked against source

2026-08-21

Cited standards

40 C.F.R. § 22.4(a) 40 C.F.R. § 22.13(b) 40 C.F.R. § 22.18(b) 40 C.F.R. § 22.18(b)(2) 40 C.F.R. § 22.18(c) 40 C.F.R. § 84.3 40 C.F.R. § 84.5(b) 40 C.F.R. § 84.5(b)(1) 40 C.F.R. § 84.5(b)(6) 40 C.F.R. § 13.13 40 C.F.R. § 13.14 40 C.F.R. § 13.17 40 C.F.R. § 13.33 42 U.S.C. § 7413(b)(2) 42 U.S.C. § 7413(c) 42 U.S.C. § 7413(d) 42 U.S.C. § 7413(d)(5) 42 U.S.C. § 7607(b)(1) 42 U.S.C. § 7675 18 U.S.C. § 1001 26 U.S.C. § 6621(a)(2)

Official source

Read the official release (epa.gov)

PDF

View Official PDF

Apply this precedent to your situation

This is citable Board precedent from 2024, and it may have been appealed since. Ezel checks how it stands today and answers your situation, with citations.

Final EAB decision

This Environmental Appeals Board Final Order is a final disposition of the enforcement proceeding. The Board ratified the Expedited Settlement Agreement/Consent Agreement, ordered Hanwha Cimarron LLC to comply with its terms, and approved a $960 civil penalty. The full text below is the official EPA release.

About this page: The plain-English summary and decision snapshot below were written by Ezel based on the official EPA EAB release. The full text is the agency's own release.

Transcribed from a scanned original: EPA EAB released this decision as an image-only file. The full text below is a machine transcription, proofread against the scan. Check the official release before quoting exact language.

Read the official release (epa.gov)

Plain-English summary

Hanwha Cimarron LLC imported 780 kilograms of the HFC blend R-407C in 60 cylinders. The shipment arrived on June 21, 2022, and the compliance activity was recorded in Atlanta, Georgia. EPA alleged that Hanwha imported the bulk regulated substances without expending the required consumption or application-specific allowances. The stipulated facts also say EPA had not issued a non-objection notice. The settlement assessed a $960 civil penalty, and Hanwha agreed to pay it within 30 calendar days of the agreement's effective date.

Decision snapshot

Cited authorities: The AIM Act, 42 U.S.C. § 7675, and implementing regulations in 40 C.F.R. parts 22, 84, and 13
Outcome: The Expedited Settlement Agreement/Consent Agreement was ratified, Hanwha Cimarron LLC was ordered to comply with its terms, and a $960 civil penalty was approved.
Key point: The alleged violation was importing bulk regulated HFCs without expending allowances equal to their exchange-value weighted quantity.

Full text (EPA EAB public release)

F I L E D
Feb 23, 2024
Clerk, Environmental Appeals Board
INITIALS ______
ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C.

)
)
In re Hanwha Cimarron LLC
) Docket No. CAA-2024-008447
)
)
)
)

FINAL ORDER

Pursuant to 40 C.F.R. § 22.18(b)-(c) of EPA’s Consolidated Rules of Practice, the attached Expedited Settlement Agreement/Consent Agreement resolving this matter is incorporated by reference into this Final Order and is hereby ratified.

The Respondent is ORDERED to comply with all terms of the Expedited Settlement Agreement/Consent Agreement, effective immediately.

So ordered.1

ENVIRONMENTAL APPEALS BOARD

Dated: February 23, 2024
________
Mary Kay Lynch
Environmental Appeals Judge

1
The three-member panel ratifying this matter is composed of Environmental Appeals Judges Aaron P. Avila, Wendy L. Blake, and Mary Kay Lynch.
ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C.

)
In re: )
) Docket No. CAA-2024-008447
Hanwha Cimarron LLC
)
)
)
)

EXPEDITED SETTLEMENT AGREEMENT

A. JURISDICTION

This is an expedited administrative penalty assessment proceeding brought under Section
113(d) of the Clean Air Act (the “Act” or “CAA”), 42 U.S.C. § 7413(d), and §§ 22.13 and 22.18 of the Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties and the Revocation/Termination or Suspension of Permits (“Consolidated Rules”) as codified at 40 C.F.R. Part 22.
Complainant is the United States Environmental Protection Agency (“EPA”). On the EPA’s
behalf, Mary E. Greene, Director, Air Enforcement Division, is delegated the authority to settle civil administrative penalty proceedings under Section 113(d) of the Act.
Respondent is Hanwha Cimarron LLC, identified further in Table 1 of ESA Attachment 1.
Complainant and Respondent (together, the “Parties”), having agreed that settlement of this
action is in the public interest, consent to the issuance of the attached final order (“Final Order” or “Order”) ratifying this expedited settlement agreement (“Agreement”) before taking testimony and without adjudication of any issues of law or fact herein, and Respondent agrees to comply with the terms of this Agreement and Final Order.
The Environmental Appeals Board is authorized to ratify this Agreement, which
memorializes a settlement between Complainant and Respondent. 40 C.F.R. §§ 22.4(a) and 22.18(b).
The Ratification of the Final Order, incorporating this Agreement, simultaneously
commences and concludes this proceeding. 40 C.F.R. § 22.13(b).
B. GOVERNING LAW
This proceeding arises under the American Innovation and Manufacturing (“AIM”) Act of
2020, 42 U.S.C. § 7675, and the regulations promulgated thereunder.
The EPA regulations at 40 C.F.R. Part 84, Subpart A, implement the AIM Act requirement to
phase down HFC production and consumption.
40 C.F.R. § 84.5(b)(l) states that “no person may import bulk regulated substances, except by
expending, at the time of the import, consumption or application-specific allowances in a quantity equal to the exchange-value weighted equivalent of the regulated substances imported.”
40 C.F.R. § 84.5(b)(6) states that “every kilogram of bulk regulated substances imported …
constitutes a separate violation of this subpart.”
```
                  C.        ALLEGED VIOLATION OF LAW
```
The EPA alleges Respondent violated 40 C.F.R. § 84.5(b) by importing the bulk regulated
substances identified in Table 1 of ESA Attachment 1 without expending consumption or
application-specific allowances in a quantity equal to the exchange-value weighted
equivalent of the regulated substances imported.
```
                       D.        TERMS OF AGREEMENT
```
For the purpose of this proceeding, as required by 40 C.F.R. § 22.18(b)(2), Respondent:

a. admits that the EPA has jurisdiction over the subject matter alleged in this
Agreement;
b. admits the facts stipulated in Table 1 of ESA Attachment 1;
c. consents to the assessment of a civil penalty as stated in Table 3 of ESA
Attachment 1 and below;
d. waives any right to contest the alleged violations of law set forth in Section C of
this Agreement; and
e. waives its right to appeal the Order accompanying this Agreement.
For the purpose of this proceeding, Respondent:

a. agrees that this Agreement states a claim upon which relief may be granted
against Respondent;
b. acknowledges that this Agreement constitutes an enforcement action for purposes
of considering Respondent’s compliance history in any subsequent enforcement
actions related to the Respondent;
c. certifies that it completed the corrective action as set forth in Table 4 of ESA
Attachment 1;
```
                                        2
```
d. waives any and all remedies, claims for relief and otherwise available rights to
judicial or administrative review that Respondent may have with respect to any
issue of fact or law set forth in this Order, including any right of judicial review
under Section 307(b)(1) of the Clean Air Act, 42 U.S.C. § 7607(b)(1);
e. consents to personal jurisdiction in any action to enforce this Agreement or Order,
or both, in the United States District Court for the District of Columbia; and
f. waives any rights it may possess at law or in equity to challenge the authority of
the EPA to bring a civil action in a United States District Court for the District of
Columbia to compel compliance with the Agreement or Order, or both, and to
seek an additional penalty for noncompliance with the Agreement or Order, and
agrees that federal law shall govern in any such civil action.
Penalty Payment. The civil penalty agreed upon by the Parties for settlement purposes is
stated in Table 3 of ESA Attachment 1. Respondent agrees to:

a. pay the penalty within 30 calendar days of the Effective Date of this Agreement;
b. pay the penalty using any method, or combination of methods, provided on the
website https://www.epa.gov/financial/additional-instructions-making-payments-
epa#Pay.gov;
c. identify each and every payment with the Docket No. of this Agreement and Final
Order; and
d. within 24 hours of payment of the penalty, send proof of payment via electronic
mail to the Inspector at the Inspector’s email address identified in Table 1 of ESA
Attachment 1. “Proof of payment” means, as applicable, a copy of the check,
confirmation of credit card or debit card payment, confirmation of wire or
automated clearinghouse transfer, and any other information required to
demonstrate that payment has been made according to the EPA requirements, in
the amount due, and identified with the docket number.
If Respondent fails to timely pay any portion of the penalty assessed under this Agreement,
the EPA may:

a. request the Attorney General to bring a civil action in the United States District
Court for the District of Columbia to recover: the amount assessed; interest at
rates established pursuant to 26 U.S.C. § 6621(a)(2), the United States’
enforcement expenses, and a 10 percent quarterly nonpayment penalty, 42 U.S.C.
§ 7413(d)(5);
b. refer the debt to a credit reporting agency or a collection agency, 40 C.F.R.
§§ 13.13, 13.14, and 13.33;
c. collect the debt by administrative offset (i.e., the withholding of money payable
by the United States to, or held by the United States for, a person to satisfy the
debt the person owes the Government), which includes, but is not limited to,
referral to the Internal Revenue Service for offset against income tax refunds, 40
C.F.R. Part 13, Subparts C and H; and
```
                                        3
```
d. (1) suspend or revoke Respondent’s licenses or other privileges, or (2) suspend or
disqualify Respondent from doing business with the EPA or engaging in
programs the EPA sponsors or funds, 40 C.F.R. § 13.17.
By signing this Agreement, Respondent certifies that the information it has supplied
concerning this matter was at the time of submission true, accurate, and complete for each
such submission, response, and statement. Respondent acknowledges that there are
significant penalties for submitting false or misleading information, including the possibility
of fines and imprisonment for knowing submission of such information, under 18 U.S.C.
§ 1001.
By signing this Agreement, Respondent acknowledges that this Agreement and Order,
including identifying information such as name, federal tax ID number, mailing and e-mail
address, will be available to the public when the Agreement and Certificate of Service are
filed and uploaded to a searchable database and agrees that this Agreement does not contain
any confidential business information or other personally identifiable information.
By signing this Agreement, the undersigned representative of Complainant and the
undersigned representative of Respondent each certify that he or she is fully authorized to
execute and enter into the terms and conditions of this Agreement and has the legal capacity
to bind the party he or she represents to this Agreement.
By signing this Agreement, Respondent agrees to acceptance of the Complainant’s: (a)
digital or an original signature on this Agreement; and (b) service of the fully executed
Agreement on the Respondent by mail or electronically by e-mail. Complainant agrees to
acceptance of the Respondent’s digital or an original signature on this Agreement.
Each party shall bear its own attorney’s fees, costs, and disbursements incurred in this
proceeding.
```
    E.       EFFECT OF AGREEMENT AND ATTACHED FINAL ORDER
```
In accordance with 40 C.F.R. § 22.18(c), completion of the terms of this Agreement and
Final Order resolves only Respondent’s liability for federal civil penalties for the violations
identified in Section C of this Agreement.
Penalties paid pursuant to this Agreement shall not be deductible for purposes of federal
taxes.
This Agreement constitutes the entire agreement and understanding of the Parties and
supersedes any prior agreements or understandings among the Parties with respect to the
subject matter hereof.
The terms, conditions, and compliance requirements of this Agreement may not be modified
or amended after it is ratified except upon the written agreement of both parties, and approval
of the Environmental Appeals Board.
```
                                          4
```
1. Any violation of this Order may result in a civil judicial action for an injunction, or civil
  penalties of up to $121,275 per day per violation (with each kilogram a separate violation), or
  both, as provided in Section 113(b)(2) of the Act, 42 U.S.C. § 7413(b)(2), as well as criminal
  sanctions as provided in Section 113(c) of the Act, 42 U.S.C. § 7413(c). The EPA may use
  any information submitted under this Order in an administrative, civil judicial, or criminal
  action.
Nothing in this Agreement shall relieve Respondent of the duty to comply with all applicable
provisions of the Act and other federal, state, or local laws or statutes, nor shall it restrict the
EPA’s authority to seek compliance with any applicable laws or regulations, nor shall it be
construed to be a ruling on, or determination of, any issue related to any federal, state, or
local permit.
Nothing herein shall be construed to limit the power of the EPA to undertake any action
against Respondent or any person in response to conditions that may present an imminent
and substantial endangerment to the public health, welfare, or the environment.
The EPA reserves the right to revoke this Agreement and settlement penalty if and to the
extent that the EPA finds, after signing this Agreement, that any information provided by
Respondent was materially false or inaccurate at the time such information was provided to
the EPA, and the EPA reserves the right to assess and collect any and all civil penalties for
any violation described herein. The EPA shall give Respondent notice of its intent to revoke,
which shall not be effective until received by Respondent in writing.
```
                             F.      EFFECTIVE DATE
```
Respondent and Complainant agree to the Environmental Appeals Board’s issuance of the
attached Final Order ratifying the Agreement. The effective date of the Agreement shall be
the date of issuance of the Final Order. The EPA will transmit a copy of the Final Order and
ratified Agreement to the Respondent.
```
                                           5
                              ESA ATTACHMENT 1
  AMERICAN INNOVATION AND MANUFACTURING (“AIM”) ACT
```
OFFSITE COMPLIANCE MONITORING ACTIVITY OR INSPECTION FACTS,
ALLEGED VIOLATIONS, PENALTY, AND CORRECTIVE ACTION FORM
```
 Table 1 – Offsite Compliance Monitoring Activity or Inspection Stipulated Facts
```
Offsite Compliance Monitoring Activity Docket Number:
or Inspection Date(s):
7/21/2022 CAA-2024-008447
Offsite Compliance Monitoring Activity Entry/Shipment Number(s):
or Inspection Location:
Atlanta, GA BTF-22134007
1
Person/Importer Name (“Respondent”) Inspector(s) Name(s) and Email Address:
and Importer Number:
Hanwha Cimarron LLC Elfego Felix
26-297802600 [email protected]
Respondent Address: Date of Detention or Hold:
4912 Moores Mill Rd 6/22/2022
Huntsville, AL 35811-1512 US
Value of Goods: Arrival Date:
$ 4,800 6/21/2022
Subject HFCs 2 and Mass (in kg): MTEVe 3:
R-407C 4 1,384
Mass: 780 kg

Did the importer have and expend Container and Quantity:
allowances equal to the imported HFCs?
No 60 cylinders, 13 kg each
Did the importer receive any non-objection The EPA Delegated Official:
notices from the EPA?
No Mary E. Greene

1
“Person” and “Importer” are defined in 40 C.F.R. § 84.3.
2
“Subject HFCs” are Bulk Regulated Substances subject to 40 C.F.R. § 84.5. “Bulk” and “Regulated Substance” are defined in 40 C.F.R. § 84.3. 3 The EPA calculates metric tons of EVe (“MTEVe”) by multiplying X kg (the mass of the regulated substance) by Y (the exchange value (EV) of the bulk regulated substance, as reflected in Appendix A of 40 C.F.R. Part 84), and dividing the product by 1,000 to obtain metric tons. The formula for calculating the EV of an HFC blend is set forth in footnote 5. 4 R-407C is an HFC blend that contains approximately 23% HFC-32, 25% HFC-125, and 52% HFC- 134a, which are regulated substances.
1
Table 2 – Description of Alleged Violation Based on the facts in Table 1, the EPA alleges that the Subject HFCs are bulk regulated substances that were imported without the importer expending consumption or application-specific allowances in a quantity equal to the exchange-value weighted equivalent of the regulated substances imported, a violation of the HFC Allocation regulations at 40 C.F.R. § 84.5(b).

2
Table 3 – Civil Penalty 5
$960, where

$4,800 * 20% = $960

Monetary Value of Goods * Percentage Multiplier = Penalty, where

 EV 6              Percentage                    HFC                   EV
                   Multiplier                    HFC–152                               53
 < 1,400           10%                           HFC–41                                92
 ≥ 1,400 ≤ 5,000   20%                           HFC–152a                             124
 > 5,000           30%                           HFC–143                              353
 ≤14,800                                         HFC–32                               675

HFC–245ca
693
HFC–365mfc
794
HFC–245fa
1,030
HFC–134a
1,100
HFC–236cb
1,340
HFC–236ea
1,370
HFC–134a
1,430
HFC–43–10mee
1,640
HFC–227ea
3,220
HFC–125
3,500
HFC–143a
4,470
HFC–236fa
9,810
HFC–23
14,800

5
To determine the EV of a HFC blend, calculate the contribution of each HFC to the total EV of the blend and calculate a case-specific EV multiplier by: multiplying the percentage of the blend made up of each HFC by its EV and summing the resulting blend constituent products to calculate the blend EV. For example, if the percentages of the blend and the EVs (in parentheses) of the constituents are: 55 percent HFC-32 (675), 16 percent HFC-125 (3,500), and 29 percent HFC-134a (1,430), the EV would be (0.55 × 675) + (0.16 × 3,500) + (0.29 × 1,430)) = 1345.95 EV. Where the exact amount or percentage of each HFC in a blend is unknown, the case team shall use the highest EV associated with a HFC in the blend as a multiplier to calculate the penalty. 6 EVs are found in Appendix A of 40 C.F.R. Part 84.
3
02/22/2024

Digitally signed by MARY
MARY GREENE

GREENE Date: 2024.02.22
18:19:49 -05'00'

SHIPPER'S DECLARATION FOR DANGEROUS GOODS (Provide at least two copies to the airline)

Shipper: HANWHA CIMARRON LLC
Air Waybill No.
4912 MOORES MILL RD
Page 1 of 1 Pages
HUNTSVILLE, AL 35811
Shipper's Reference Number (optional)
USA

Consignee: E-DO CO., LTD
#704, SAMYANG SMART TECHNOPARK 13, GONGDAN
1-DAERO
SIHEUNG-SI, GYEONGGI-DO
15086, REPUBLIC OF KOREA

BUREAU OF DANGEROUS GOODS
powered by ShipHazmat.NET

Two completed and signed copies of this Declaration must be handed to the operator

WARNING
Failure to comply in all respects with the applicable Dangerous Goods Regulations may be in breach of the applicable law, subject to legal penalties.

TRANSPORT DETAILS
This shipment is within the limitations prescribed for (delete non-applicable): PASSENGER AND CARGO AIRCRAFT / CARGO AIRCRAFT ONLY Airport of Departure: Airport of Destination: Shipment Type (delete non-applicable): NON-RADIOACTIVE / RADIOACTIVE

Additional Handling Information
24-Hour Emergency Contact Telephone Number: CHEMTEL:+1-813-248-0585
MIS9516320 - PROPACK INTERNATIONAL
-PREPARED IN ACCORDANCE WITH IATA/ICAO

I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked and labelled/placarded, and are in all respects in proper condition for transport according to applicable international and national governmental regulations. I declare that all of the applicable air transport requirements have been met.

Name of Signatory: DANIEL COX
Date: August 31, 2022
Signature (see warning above)

988 ATL 4492 8310 988-44928310
Shipper's Name and Address Shipper's Account Number Not Negotiable BNX SHIPPING-ATLANTA, INC 3460 SUMMIT RIDGE PKWY, STE 601 Air Waybill ASIANA AIRLINES DULUTH, GA 30096 UNITED STATES
Issued by

Copies 1.2 and 3 of this Air Waybill are originals and have the some validity.
Consignee's Name and Address Consignee's Account Number It is agreed that the goods described herein are accepted in apparent good order and condition
TRIDENT INTERNATIONAL (KOREA) LTD
except as noted for carriage SUBJECT TO THE CONDITIONS OF CONTRACT ON THE
REVERSE HEREOF. ALL GOODS MAY BE CARRIED BY ANY OTHER MEANS INCLUDING
ROOM 1001, 74, SEJONG-DAERO, JUNG-GU
ROAD OR ANY OTHER CARRIER UNLESS SPECIFIC CONTRARY INSTRUCTIONS ARE
SEOUL, 04526 KOREA, REPUBLIC OF
GIVEN HEREON BY THE SHIPPER, AND SHIPPER AGREES THAT THE SHIPMENT MAY BE
ATTN:[email protected]
CARRIED VIA INTERMEDIATE STOPPING PLACES WHICH THE CARRIER DEEMS
APPROPRIATE. THE SHIPPER'S ATTENTION IS DRAWN TO THE NOTICE CONCERNING
TEL:82-2-778-0880 FAX:82-2-778-2680
CARRIER'S LIMITITATION OF LIABILITY. Shipper may increase such limitation of liability by
declaring a higher value for carriage and paying a supplemental charge if required.
Issuing Carrier's Agent Name and City
Accounting Information
BNX SHIPPING-ATLANTA, INC
[NOTIFY]
3460 SUMMIT RIDGE PKWY, STE 601
TRIDENT INTERNATIONAL (KOREA) LTD
DULUTH, GA 30096 UNITED STATES
ROOM 1001, 74, SEJONG-DAERO, JUNG-GU
SEOUL, 04526 KOREA, REPUBLIC OF
Agent's IATA Code Account No. ATTN:[email protected]
01-19180/0061
TEL:82-2-778-0880 Fax:82-2-778-2680
Airport of Departure (addr. of First Carrier) and Requested Routing Filling No. Optional Shipping Information
ATLANTA HARTSFIELD
AAE-15206
To By First Carrier Routing and Destination to by to by Currency CHGS
Code WT/VAL Other Declared value for Carriage Declared value for Customs
PPD COLL PPD COLL
ICN ASIANA AIRLINES USD PP X X
Airport of Destination Requested Flight/Date Amount of Insurance INSURANCE - If carrier offers insurance, and such insurance is request in
accordance with the conditions thereof, indicate amount to be insured in
INCHEON AIRPORT OZ-247 / 03 fiqures in box marked Amount of Insurance . Handling Information

DANGEROUS GOODS AS PER ATTACHED DGD
SCI
These commodities, technology or software were exported from the United States in accordance with Diversion contrary to U.S. X the Export Administration Regulations. Ultimate Destination KOREA, REPUBLIC OF law prohibited.
No. of
Rate Class
Gross kg Chargeable Rate Nature and Quantity of Goods
Pieces Commodity Total
Weight lb Weight Charge incl. Dimensions of Volume
RCP
Item No.

1 874.0 K 874.0 K CONSOLIDATED SHIPMENT AS PER ATTACH
6.90
6,030.60
PIECE(S) 1,927.0 L 1,927.0 L ED CARGO MANIFEST

1 874.0 K
6,030.60
PIECE(S) 1,927.0 L
FREIGHT PREPAID
Prepaid Weight Collect Other Charges PREPAID COLLECT

                      6,030.60                                                                       MYC                                                           1,223.60

SCC
87.40
Valuation Charge
XBC
87.40
RAC
100.00
Tax

Total Other Charges Due Agent
Shipper certifies that particulars on the face hereof are correct and that insofar as any part of the
consignment contains dangerous goods, such part is properly described by name and is in proper condition
0.00
for carriage by air according to the applicable Dangerous Goods Regulations.
Total Other Charges Due Carrier
BNX SHIPPING-ATLANTA, INC
1,498.40
AS AGENT OF BNX SHIPPING-ATLANTA, INC

Signature of Shipper or Agent
Total Prepaid
Total Collect
BNX SHIPPING-ATLANTA, INC
7,529.00
AS AGENT OF THE ASIANA AIRLINES
Currency Conversion Rates
CC Charges in Dest, Currency
01-Sep-2022 17:17 ATLANTA HARTSFIELD CLAIRE JEONG
Executed on date at place Signature of Issuing Carrier or Agent

Charges at Destination
Total Collect Charges
For Carrier's Use Only
at Destination
988-44928310
FOR CONSIGNEE
988 ATL 4492 8310 AAEH-43834 Shipper's Name and Address Shipper's Account Number Not Negotiable
HANWHA CIMARRON LLC
BNX SHIPPING-ATLANTA, INC
4912 MOORES MILL RD Air Waybill 3460 SUMMIT RIDGE PKWY, STE 601
HUNTSVILLE, AL 35811 UNITED STATES
DULUTH, GA 30096 UNITED STATES
Issued by

Agent's IATA Code
Account No.
01-19180/0061
Airport of Departure (addr. of First Carrier) and Requested Routing Filling No. Optional Shipping Information
ATLANTA HARTSFIELD
AAE-15206
CHGS
To By First Carrier Routing and Destination to by to by Currency Code WT/VAL Other Declared value for Carriage Declared value for Customs
PPD COLL PPD COLL
ICN KOREAN AIRLINE USD CC X X N.V.D. $4,800.00
Airport of Destination Requested Flight/Date Amount of Insurance INSURANCE - If carrier offers insurance, and such insurance is request in
accordance with the conditions thereof, indicate amount to be insured in
INCHEON AIRPORT OZ-247 / 03 N.I.L fiqures in box marked Amount of Insurance . Handling Information

SCI
These commodities, technology or software were exported from the United States in accordance with Diversion contrary to U.S. the Export Administration Regulations. Ultimate Destination KOREA, REPUBLIC OF law prohibited. X
No. of
Rate Class
Gross kg Chargeable Rate Nature and Quantity of Goods
Pieces Commodity Total
Weight lb Weight Charge incl. Dimensions of Volume
RCP
Item No.

1 874.0 K 874.0 K SAID TO CONTAIN:
AS ARRANGED
PIECE(S) 1,927.0 L 1,927.0 L MIXED REFRIGERANT R407C FOR SPRAY
COATING MACHINE
53IN X 43IN X 58IN 1PIECE(S)
PO# 45640

ENTRY NO. 256090586

1
874.0 K
PIECE(S) 1,927.0 L FREIGHT COLLECT
Prepaid Weight Collect Other Charges PREPAID COLLECT

AS ARRANGED
Valuation Charge

Tax

Total Other Charges Due Agent
Shipper certifies that particulars on the face hereof are correct and that insofar as any part of the
consignment contains dangerous goods, such part is properly described by name and is in proper condition for carriage by air according to the applicable Dangerous Goods Regulations.
Total Other Charges Due Carrier
BNX SHIPPING-ATLANTA, INC
AS AGENT OF HANWHA CIMARRON LLC

Signature of Shipper or Agent
Total Prepaid
Total Collect
BNX SHIPPING-ATLANTA, INC
AS ARRANGED
AS AGENT OF THE CARRIER KOREAN AIRLINE
Currency Conversion Rates
CC Charges in Dest, Currency
18-Aug-2022 ATLANTA HARTSFIELD CLAIRE JEONG
Executed on date at place Signature of Issuing Carrier or Agent

Charges at Destination
Total Collect Charges
For Carrier's Use Only
at Destination
AAEH-43834
FOR CONSIGNEE

U.S. Customs and Border Protection
OMB APPROVAL NO. 1651-0003
TRANSPORTATION ENTRY AND MANIFEST OF
EXPIRATION DATE 01/31/2021
GOODS SUBJECT TO CBP INSPECTION AND PERMIT ESTIMATED BURDEN 10 MIN 19 CFR 10.60, 10.61

Entry No.
Entry No. 256090586
Port
Class of Entry 63 I. E.
Date
(I.T.)(T.E.)(WD.1 E)(Drawback, etc.)
PORT CODE NO. 1704
FIRST U.S. PORT OF UNLADING ATLANTA, GA
PORT OF ATLANTA, GA
DATE 08/26/2022
Entered or Imported by HANWHA CIMARRON LLC Importer/IRS # 26-297802600 to be shipped
V/F/T 0261 in bond via 95-418337700 OZ ASIANA AIRLINES consigned to
(C.H.L. number) (Vessel or carrier) (Car number and initial) (Pier or station) CBP Port Director 1704 - ATLANTA, GA Final Foreign Destination 58029 - INCHON; JINSEN, REP. O (For exportations only) Consignee HANWHA CIMARRON LLC / 4912 MOORES MILL RD / HUNTSVILLE AL 35811 (At CBP Port of exit or destination) Foreign Port of Lading 58029 - INCHON; JINSEN, REP. OF KO B/L No. 18094549792 Date of sailing (Above information to be furnished only when merchandise is imported by vessel) Imported on the Flag on via (Name of vessel or carrier and motive power) (Date imported) (Last foreign port) Exported From on Goods now at (Country) (Date) (Name of warehouse, station, pier, etc.)

Marks and Number of Packages | Description and Quantity of Merchandise; Number and Kind of Packages (Describe fully as per shipping papers) | Gross Weight in Pounds | Value (Dollars only) | Rate | Duty QP IN-BOND AUTHORIZED QP01256090586 B/L No.: 18094549792 H/B No.: ESS852772 totals for B/L: 1,720 LBS $4,800 1 MIXED REFRIGERANT R407C FOR SPRAY COATING MACHINE EXPORT MASTER# : 988-44928310 EXPORT HOUSE# : AAEH-43834 ATL DEPART : 9/3/22 ICN ARRIVE : 9/4/22
Tariff #: 3827.64.0000
1,720 LBS $4,800
Trans #: 109352180 Shipper Ref#: 256090586

G.O. No. Check if withdrawn for Vessel supplies (19 U.S.C. 1309)
CERTIFICATE OF LADING FOR TRANSPORTATION IN BOND AND/OR LADING FOR EXPORTATION FOR (Port) WITH THE EXCEPTIONS NOTED ABOVE, THE WITHIN-DESCRIBED GOODS WERE: Delivered to the carrier named above, for delivery to the CBP Port Director at destination sealed with CBP seals Nos. or the packages (were) (were not) labeled, or corded and sealed. Laden on the-- (Vessel, vehicle or aircraft) which cleared for-- on (Date) as verified by export records.

I truly declare that the statements contained herein are true and correct to the best of my knowledge and belief. Entered or withdrawn by K&G CUSTOMS SERVICE INC 5935 BUFORD HIGHWAY SUITE 300 NORCROSS, GA 30071

To the Inspector: The above-described goods shall be disposed of as specified herein. For the Port Director Received from the Port Director of the above CBP location the merchandise described in this manifest for transportation and delivery into the custody of the CBP officers at the port named above, all packages in apparent good order except as noted hereon. ASIANA AIRLINES / EIN# 95-418337700 Attorney or Agent of Carrier
CBP Form 7512 (01/21)
Page 1 of 2

Marks and Number of Packages | Description and Quantity of Merchandise; Number and Kind of Packages (Describe fully as per shipping papers) | Gross Weight in Pounds | Value (Dollars only) | Rate | Duty SHIPPER: E-DO CO LTD
#704, SAMYANG SMART TECHNOPARK 13,
GONGDAN 1-DAERO SIHEUNG-SI, GYEONGGI
REPUBLIC OF KOREA
Trans #: 109352180 Shipper Ref#: 256090586

I certify that copies of the foregoing “Expedited Settlement Agreement/Consent Agreement” and “Final Order,” in the matter of Hanwha Cimarron LLC, Docket No. CAA-2024- 008447, were sent to the following persons in the manner indicated:

By E-mail:

Ethan Thompson, Attorney Advisor
Air Enforcement Division
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460
e-mail: [email protected]

Wesley Wells
Hanwha Cimarron LLC
4912 Moores Mill Rd
Huntsville, AL 35811
e-mail: [email protected]

Feb 23, 2024
Dated: ____
______
Annette Duncan
Administrative Specialist

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