Liferafts Incorporated of P.R. (Board decision, July 12, 2024)

Read the official release (epa.gov)

Plain-English summary

Liferafts Incorporated of P.R. imported 73 cylinders containing bulk HFCs, including HFC-134a and the blends R-404A, R-407C, and R-407F. EPA alleged that the shipment entered Puerto Rico without the importer expending the required consumption or application-specific allowances and without an EPA non-objection notice. The shipment had an estimated value of $92,586 and an exchange-value equivalent of 6,004 metric tons. The settlement approved an $18,517 civil penalty and corrective action addressing the subject HFCs.

Decision snapshot

• Cited authorities: The AIM Act and Clean Air Act, 42 U.S.C. §§ 7413 and 7675, with implementing regulations in 40 C.F.R. parts 13, 19, 22, and 84
• Outcome: The Expedited Settlement Agreement and Consent Agreement were ratified, Liferafts was ordered to comply with their terms, and an $18,517 civil penalty was approved.
• Key point: Importers of bulk regulated HFCs must use the required allowances or obtain the required EPA non-objection notice.

Full text (EPA EAB public release)

FILED

Clerk, Environmental Appeals Board
a ae
INITIALS _ ct

ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.

In re Liferafts Incorporated of P.R. Docket No. CAA-2024-8452

ee a a

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 Consent Agreement, effective immediately.

So ordered.!
ENVIRONMENTAL APPEALS BOARD

Dated: July 12, 2024 Lif

Aaron P. Avila
Environmental Appeals Judge

' The two-member panel ratifying this matter is composed of Environmental Appeals Judges Aaron P. Avila and Mary Kay Lynch.

ENCLOSURE

AMERICAN INNOVATION AND MANUFACTURING ACT EXPEDITED
SETTLEMENT AGREEMENT/CONSENT AGREEMENT AND FINAL ORDER

ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.

)
Inre: )

) Docket No. CAA-2024-8452
Liferafis Incorporated of P.R. )

)

)

)

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/Tennination 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 Liferafts Incorporated of P.R. identified further in Table 1 of Expedited Settlement Agreement (“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 conscnt 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 the Parties. 40 C.F.R. §§ 22.4(a) and 22.18(b).

. The Ratification the Final Order, incorporating this Agreement, simultaneously commences and concludes this proceeding. 40 C.F.R. § 22.13(b).

In re: Liferafts Incorporated of P.R.
Docket No. CAA-2024- 8452

B. GOVERNING LAW

7. This proceeding arises under the American Innovation and Manufacturing (“AIM”) Act of
   2020, 42 U.S.C. § 7675, and the regulations promulgated thereunder.

8. The regulations at 40 C.F.R. Part 84, Subpart A, implement the AIM Act requirement to
   phase down HFC production and consumption.

9. 40 C.F.R. § 84.5(b)(1)(i) states, in relevant part, that “[no person may import bulk regulated
   substances, cither as a single component or a multicomponent substance, except . . . [i]f the importer of record possesses at the time they are required to submit reports to EPA pursuant to § 84.31(c)(7), and expends at the time of ship berthing for vessel arrivals, border crossing fer land arrivals such as trucks, rails, and autos, and first point of terminus in U.S. jurisdiction for arrivals via air, consumption or application-specific allowances in a quantity equal to the exchange-value weighted equivalent of the regulated substances imported, whether prcsent as a single component or a multicomponent blend.”

10. 40 C.F.R. § 84.5(b)(7) states, in relevant part, that “[e]very kilogram of bulk regulated
    substances imported contrary to [§84.5(b)] constitutes a separate violation of this subpart.”

C. ALLEGED VIOLATION OF LAW

11. The Complainant alleges that Respondent violated 40 C.F.R. § 84.5(b) by importing the bulk
    regulated substances identified in Table | of ESA Attachment | without expending consumption or application-specific allowances in a quantity equal to the exchange value equivalent of the regulated substances imported.

Dz. TERMS OF AGREEMENT

12. 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 tacts stipulated in Table | of ESA Attachment 1;

c. consents to the assessment of a civil penalty as stated in Table 3 of ESA Attachment | 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.

13. For the purpose of this proceeding, Respondent:

a. agrees that this Agrecment states a claim upon which relief may be granted against Respondent;

wv

In re: Liferatts Incorporated of P.R.
Docket No. CAA-2024- 8452

acknowledges that this Agreement constitutes an enforcement action for purposes of considering Respondent’s compliance history in any subsequent enforcement actions related to Respondent;

certifies that Respondent completed the corrective action as set forth in Table 4 of ESA Attachment 1;

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 issuc 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);

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 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 Agrcement 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.

14. 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.

b.

pay the penalty within thirty (30) calendar days of the Effective Date of this Agreement; pay the penalty using any method, or combination of methods, provided on the website https: www.epa.gov/tinancial‘additional-instructions-making-payments- epatPay vow: identify each and every payment with the Docket No. of this Agreement and Final Order; and within twenty-four (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 rable | of ESA Attachment |. “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.

15. 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 ten (10) percent quarterly nonpayment penalty, 42 U.S.C. § 7413(d)(5);

16,

20.

21.

In re: Liferafts Incorporated of P.R.
Docket No. CAA-2024- 8452

b. refer the debt to a credit reporting agency or a collection agency, 40 C.F.R.
§§ 13.13, 13.14, and 13.33,
co 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

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 fer 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 infortnation, 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 1D 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 they are fully authorized to execute and enter into the terms and conditions of this Agreement and has the legal capacity to bind the party they represent to this Agreement.

. By signing this Agrecment, Respondent agrees to accept the Complainant’s: (a) digital or

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 accept the Respondent’s digital or 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.

22.

235

24.

26.

27.

28.

29.

In re: Liferafts Incorporated of P.R.
Docket No. CAA-2024- 8452

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.

. 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 | 13(b)(2) of the Act, 42 U.S.C. § 7413(b)(2), as well as criminal sarctions 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 rescrves 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.

ri 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.

In re: Liferafts Incorporated of P.R.
Docket No. CAA-2024-8452

ESA ATTACHMENT 1

AMERICAN INNOVATION AND MANUFACTURING (“AIM”) ACT
ON-SITE COMPLIANCE MONITORING ACTIVITY OR INSPECTION FACTS, ALLEGED VIOLATIONS, PENALTY, AND CORRECTIVE ACTION FORM

Table 1 —- On-site Compliance Monitoring Activity or Inspection Stipulated Facts

On-site Compliance Monitoring Activity
or Inspection Date(s):

Docket Number:

March 12, 2024

| CAA-2024-8452

On-site Compliance Monitoring Activity
or Inspection Location:

Entry/Shipment Number(s):

Guaynabo, Puerto Rico

| D84-00821 46-7

Person/Importer! Name (“Respondent”)
and Importer Number:

Inspector(s) Name(s) and Email Address:

Liferafts Incorporated of P.R.
66-0352 12400

Richard Kan — [email protected]
Julian Velez — velez.julian(@epa.gov
Elfego Felix - [email protected]

Respondent Address:

Date of Detention or Hold:

Street B, Lot No. 21
Sabano Abajo Industrial Park
Carolina, Puerto Rico 00982

March 12, 2024

Estimated Value of Goods:

Arrival Date:

$92,586

| On or about February 28, 2024

Subject HFCs? and estimated Mass (in kg):

MTEVe?:

HFC-134a (519 kg)
R-404A (939 kg)*
R-407C (471 kg)®
R-407F (408 kg)°

6,004

Did the importer have and expend
allowances equal to the imported HFCs?

Container and Quantity:

No

| 73 cylinders

Did the importer receive any non-objection
notices from the EPA?

The EPA Delegated Official:

No

| Mary E. Greene

' “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 (FV) 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 7.

*R-404A is a refrigerant blend that contains the following regulated substances: HFC-125, HFC-134a, and HFC- 143a.

5 R-407C is a refrigerant blend that contains the following regulated substances: HFC-32, HFC-125, and HFC-134a, 6 R-407F is a refrigerant blend that contains the following regulated substances: HFC-32, HFC-125, and HFC-134a.

° Digitally signed by
VLE Yd MARY MARY GREENE |
Date: 2024.07.11
GREENE o:sa-5e-04-00

In re: Liferafts Incorporated of P.R.
Docket No. CAA-2024-8452

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, in a violation of the HFC Allocation regulations at 40 C.F.R. § 84.5(b).

Table 3 — Civil Penalty’

$18,517, where

$92,586 * 20% = $18,517

Monetary Value of Goods * Percentage Multiplier = Penalty, where

EV 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-245 fa 1,030
HFC-134 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
HEC—143a 4,470
HFC~236fa 9,810
HFC~23 14,800

{ Table 4 — Corrective Action

• Ta 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.

S EVs are found in Appendix A of 40 C.F.R. Part 84.

nN

In re: Liferafts Incorporated of P.R.
Docket No. CAA-2024-8452

Respondent certifies that it has:

M% © exported the Subject HFCs to
lal name and address

(including country) of the recipient of the exports], a country other than Canada or Mexico (unless the point of entry to the U.S. for the Subject HFCs was through Canada

or Mexico) and

x paid $f 3353. 2 F ] to perform the above action to address the Subject HFCs, and enclosed a record documenting such payment.

Respondent must check the boxes, fill in all relevant hlanks, and return any enclosures and this Attachment I with the signed Agreement.

In re: Liferafts Incorporated of P.R.
Docket No. CAA-2024-8452

The foregoing Agreement In the Matter of Liferafts Incorporated of P.R., Docket No. CAA- 2024-8452 is Hereby Stipulated, Agreed, and Approved.

FOR COMPLAINANT:

MARY pier
Date: 2024.06.28

GREENE 62843 -04'00

Mary E. Greene, Director

Air Enforcement Division

Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency

FOR RESPONDENT:

Li, ZEET 24 Savg D004

Signature Date

Printed Name: LEG
Title: __ CoMPTRELLER
Address: tReet 6, Lo7 Wo. 2), sAbwwe AbATD Tous, bs, CAkotuy, Pk HZ

Federal Tax Identification Number: A 6035 2)2 yy

Hazmat Transportation Solutions
31 Street #Gg-7

Rio Grande Estates

Rio Grande, Puerto Rico 00745
Tel: 787.887.7953

BILL TO

Liferafts Incorporated of Puerto Rico
PO Box 9022081

San Juan, Puerto Rico 00902-2081

Tel: 787.723.3237
Attention: Accounts Payable Department

"DESCRIPTION

MuttiModa! Dangerous Goods Declarations "Ocean" Mode
| Consignee: Wilhelmsen Ships Services S.A. (Panama)
Emergency Response Communication Service Fee

Telephone Fee

PAID IN FULL (ATH Movil)

Invoice
DATE INVOICE #
444112024 8082
DUE DATE P.O. NUMBER
4111/2024
‘ty | Rate | AMOUNT
| 2 150.00 | 300.00
1 60.00 | 60.00
1 10.00 | 10.00
|
|
'
|
| |
|
|
Total 370.00

PIER 17 PUERTO RICO LLC
1767 AVE. JESUS T. PINERO,

SUITE B URB. SUMMIT HILLS

SAN JUAN, PR 00920

787-945-2019
787-780-4814

Voice:
Fax:

INVOICE

Invoice Number: 24/2765
invoice Date: Apr 18, 2024
Page: 1

Duplicate

Bil

| | Ship to:

LIFERAFTS INCORPORATED OF PUERTO
RICO

CALLE B, LOTE NO.21

SABANA ABAJO INDUSTRIAL PARK
CAROLINA, PR 00982

_ RICO

LIFERAFTS INCORPORATED OF PUERTO

| CALLE B, LOTE NO.21
SABANA ABAJO INDUSTRIAL PARK
CAROLINA, PR 00982

CONSOLIDATION#4 1/2024,
MANIFEST#2024/49, VESSEL: GERHARD
SCHULTE V: 2048,

| CONTAINER#TCKU 11497 72(73 PKG)

“CustomerID
EE ore 33420811
7 senuanes SCHULTE 4/18/24
THEE CHARGES

Check/Credit Memo No:

1,00 | OCEAN FREIGHT “OCEAN FREIGHT 1,675.00 1,675.00
4.00 IMO CHARGE 300.00 300.00
1.00 SEAL 40.00 | 10.00.
1.00 VGM 25.00 25.00.
1.00 DOC DOCUMENTATION CHARGE 55.00 55.00
1.00 AES/SED 35.00 35.00
1.00 “TRANSFER CASTILLO AL TERMINAL 475.00 | 175.00
4.00, CHASSIS 125.00 125.00
EXPORT FROM SAN JUAN PR TO
MANZANILLO
4/18/24 JCC
Subtotal 7 2,400.00 |
| Sales Tax oo
“Total Invoice Amount - 2,400.00

Payment/Credit Applied _

_ TOTAL,

PIER 17 PUERTO RICO LLC
1767 AVE. JESUS T. PINERO,

INVOICE

SUITE B ,URB. SUMMIT HILLS invoice Number: 24/2457
SAN JUAN, PR 00920 invoice Date: Mar 1, 2024
Page: 4
Voice: 787-945-2019 Duplicate
Fax: 787-780-4814
LIFERAFTS INCORPORATED OF PUERTO | LIFERAFTS INCORPORATED OF PUERTO
| RICO — RICO
CALLE B, LOTE NO.21 CALLE B, LOTE NO.21
SABANA ABAJO INDUSTRIAL PARK | SABANA ABAJO INDUSTRIAL PARK CAROLINA, PR 00982 | CAROLINA, PR 00982 | “ Customer!D om LIFERAFTSPR 33120811 “Sales Rep Shipping Method GERHARD SCHULTE
[Quantity |. Item ~ Description _
HBL CHARGES
CONSOLIDATION#4 1/2024,
MANIFEST#2024/49, VESSEL: GERHARD
SCHULTE V: 2048,
| CONTAINER#TC KU 1149772(73 PKG) |
1,00 | AGENCYFEE “AGENCY FEE 173.68 | 173.58
1.00 “CONGESTION SURCHARGE 34.72 34.72
4.00 PORTCHARGES PORT CHARGES 25.00 25.00
1.00. IMPORT FEE 30.00 30.00
4.00 |CODFEE COD FEE (3%) 7.89 7.89
1.00 | DOC DOCUMENTATION CHARGE 35.00 35.00
4.00 | THC TERMINAL HANDLING CHARGE 208.20 208.20
($30/CBM) (MIN $75)
4.00 | HANDLING HANDLING CHARGE ( $20/CBM) (MIN $50) 138.80 438.80 4.00 SCANNING SCANNING FEE (MIN $10) 19.08 | 19.08 1.00 CHASSIS CHASSIS FEE (MIN $6- MAX $11) 11,00 11.00 1.00 AMS TRANSMISSION AMS TRANSMISSION CHARGE 25.00 25.00 1.00 IMO CHARGE 75.00 75.00 1.00 CORRECCION DE HACIENDA 25.00 25.00 REF:73 PKG, SHIP SUPPLIES HAZARDOUS, 3810KGS /6.94CBM
_ Subtotal Continued
ales Tax Continued
“Total | nveice Amount Continued
Check/Credit Memo No: Payment/Credit Applied i
TOThE 6 es é ontinued |

OER Ermer INVOICE

SUITE B ,.URB. SUMMIT HILLS Invoice Number: 24/2457

SAN JUAN, PR 00920 Invoice Date: Mar 1, 2024
Page: 2

Voice: 787-945-2019 Duplicate

Fax: 787-780-4814

Bill To: ee ‘| "Ship to: -

LIFERAFTS INCORPORATED OF PUERTO | LIFERAETS INCORPORATED OF PUERTO RICO RICO

CALLE 8, LOTE NO.21 i | CALLE B, LOTE NO.21
| SABANA ABAJO INDUSTRIAL PARK | SABANA ABAJO INDUSTRIAL PARK
| CAROLINA, PR 00982 CAROLINA, PR 00982
i
an LIFERAFTSPR 33120811 ;
= Sales RepiDs “= Shipping Method Due Date
L "GERHARD SCHULTE 3/1/24
: tem : ae: Description - x
3/7/24 JCC
|
Subtotal ; 808.27
Sales Tax :
Total Invoice Amount _ 808.27
Check/Credit Memo No: Payment/Credit Applied

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Gy ity Address (Getrier ne responsible for Buono ~~" Seaelgned s Meferedse: ~ Ze SAME AS CONSIGNEE as DALKIS MAGALLON Biaee OF RECEIDL: Be WSS-PTY- LOGISTICS@WILHELMSEN . COM Ys +507-304-6300 Uy [westenee Voyage-No.: Yi SLS AZURE ZALES [Place of Delivery,

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'san JUAN, PUERTO RICO

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& MANZANILLO (PA)

ge (Container Nos., Seal Nos; Marks and Nae” Thumber and Kind of Packages, Descripian of Goods . [Gross Warght: |Measuremtont
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sae 1 CONT. 20'X8'6" GENERAL PURPOSE CONT. SLAC*
‘s | HLXU 1126926 73 CYLINDERS 3773.0

= SEALS : LOADED ON 4 PALLETS KGM
=z (UL7033 589 UNICOOL REFRIGERANT MIXTURES

« | CBPMSS25684 BES :X20240423437941

Py HS CODES:

¥ 3827.61.0000

3827.64.0000

Ge 2901.45.1000
yy =
Y 3340
Y Bp
Y CLASS 2.2
HS-CODE : 38 27 61

SSNS

as dectared by Shipper, Without responsibilily

Shipper’s deciared Vaiue [see ciause Hai and 735}
correctness by Cartier [see clause 14} DRAFT

4 a Total No. of Containers received oy ine Camer ckages received by the Carer sisson near

Bhd i sant good order and condition (ucless
é fol 1 i —— y of Comtainers ef other packages or
See Rovemant TCurency ~ HAS ee “To of Containers) *eckagea received by 99 H 7 i the terms and condiffans heres? INCLUDING THE we ON THE REVERSE HEREOF AND THE TERMS AND CONDI- SoS. (CRarge [Baie APPLICABLE TARIFF) from the Place of Racenpt or the Por of ey, i abie te the Port of Discharge of the Place of Delivery, whch: ae i a | Sea Winybal the Merchant axptessly accepts and agrens tAF; 16 whether pinied, stamped or wikinn, OF olhenvisa Incapa.

ve nereeighing of this Soa Waybil by the Merenant

BRS RE OF RGR
PONCE O1.MAY.2024
Freight payable at
ORIGIN

FOR ABOVE NAMED CARRIER,
L.A. AYALA COLON (AS AGENT)

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Hapag-Lloyd

Page 3 / 3
SWB-No. HLCUPSE240451494

*SLAC = Shipper's Load, Stow, Weight and Count

SHIPPED ON BOARD, DATE : O1.MAY.2024
PORT OF LOADING: SAN JUAN, PUERTO RICO
VESSEL NAME: SLS AZURE VOYAGE: 24168

PORT CHARGE ORIGIN PREPAID
SEAFREIGHT + ADDITIONALS PREPAID
PORT CHARGE DESTINATION PREPAID

Rank Shinping of P.R Inc.

Date @5/06/2024 Time 10:17 AN In-Bond Arrival/Export/Liability Transfer/Diversion (WT) Page Ref # In-Bond $ ANB/BL # Container # Action Cd Message Code and Description 452994 170325013 Export entire In-Bond @2 (274) DATA ADDED AS REQUESTED

Date: 05/85/24 Time: 18:42 Port: 4909 Carrier:

Rank Shipping of P.R Inc,
Date 05/06/2824 Tine 10:17 AN In-Bond Notification Status (NS) Paget

In-Bond #: 170325013 Ref #: 452991 -In-Bord type: 63
U.S. Port of Dastination: 4909 Foreign Destination: 22556 Master AWB: MAEUZ36518885 Qty: 73 Carrier: OMTF Disposition: (58) EXPORT OF IN-BOND COMPLETE MO Date: 05/25/24 Tine: 16:42 YEMENT Entry #2 178325013 Entry Type: 63 Port: 4909 FIRMS Code: N744 Container #: Remarks: INBOND EXPORTED ON 24885 AT 4909

Container #: TCKUIL49772 Seal fi: 009007744 Seal #2;

DEPARTMENT OF HOMELAND SECURITY
U.S. Customs and Border Protection

APPLICATION AND APPROVAL

TO MANIPULATE, EXAMINE, SAMPLE OR TRANSFER GOODS yan \esoone 49 CFR 19.8, 19.11, 158.43 Exp 06-31-2020 4, GOOBS GCONSIGNER TO (Name) 2, GOODS EXPORTED FROM 3. PORTIPORT CODE AND DATE OF APPLICATION ANTWERP,BELGIUM LIFERAETS INCORPORATED OF P.R 4909/04-16-2024

4. LOCATION OF GOODS 5. CARRIER OR SHIP (Name) 6. BILL OF LADING OR GBP 7512 NO,
   MAEU236518885
   N744-DEL CASTILLO WHSE GERHARD SCHULTE 2048 HB/L PSPQ33120611 71S AREA BONDED? 8. ENTRY INFORMATION Number:

Yes (no

Cl Warehouse a Consumption Date:

ETD: 03-27-2022

PERMISSION IS REQUESTED TO: (Describe the complete operation to be performed under CBP supervision on the goods listed below):

73 Pkgs UNICOOL Refrigerant Mixtures to be loaded on a 20' container.

FOR CBP USE ONLY

9, MARKS AND NUMBERS

10. DESCRIPTION

41, MANIPULATED VALUE.

AS ADDRS.

73 Pkgs UNICOOL Refrigerant Mixtures containig
HFCS: (R-404A 45KG, R404A 9.5KG, R-407C 52KG,
R-404F 57KG, R-134a 57KG, R-134a 12.5KG,
R-404C 11KG)

WE HEREBY REQUEST PERMISSION TO
LOAD MERCHANDISE MENTIONED ABOVE

ON A 20' CONTAINER UNDER CUSTOMS
SUPERVISION.

WE GUARANTEE PAYMENT UNDER OUR
BOND NO. 66-0422836.

12. SIGNATURE OF APPLIGANT HILDARIS M RIVERA Stabe snes vy ribamsns
    aye
    RANK SHIPPING OF P.R.INC, ATTY. INFACT: VABADA ee qora 04 38-0490" APPROVED
13. DATE y y 74, SIGNATURE AND THLE OF APPROVING CBP OFFICER
    ffl PS GORY Abo

See Page 2 of torm for Paperwork Reducion Act Nottce. Customs and Border Protection Officers Report on Reverse CBP Form 3499 (12/18) o {

CUSTOMS AND BORDER PROTECTION OFFICER'S REPORT

| Date: af /t3 [22 ry
: CBP (warehouse) officer will report
MANIPULATION COMPLETED AS REQUESTED: When goods are repacked the hereon the marks and numbers of packages repacked and the marks and numbers of packages and the weights or

guage of same after repacking.
23 hyel4|L7 73 Pees VNigeee Rebrigeradt Ai Y/e3/ey
Wie Ci ff. OFFo_ Aes

=| Ieedure Refused by GPO
090° br| “CBPO Gea jo _ be Cxeorted

unser CBP Suparwes Tan,

Lotainer ULXVINE CALS
039 Seat ASS ASE BH

I

oN

a
a SN
— =<
“CB,
FE >
oo

ne

NN

(CAP Officer “ri —en LELELALIEE ‘ LBP? e } a3 ) w

PAPERWORK REDUCTION ACT STATEMENT: An agency may nol conduct ar spansor an information collection and a person is not required to raspond to this information unless it displays a current valid OMB contol number and an expiration date. The control number for this collection is 1651-0006, Obligation to respond Is requirect to obtaln benefits. The estimated average time to compiete this application is 6 minutes. If yau have any comments ragarding the burden estimate you can writa to PRA Clearance Officer, U.S. Customs and Border Protection, Office of Rogutations and Rulings, 80 K Street NE. Washinaton OC 20228.

CBP Form 3499 (12/16)

REF #: 452991 LOG #
OM 8 No 1654-0003

Entsy No 120328013.

19 CER 18.60, 1065, 123 41, 123.82 TRANSPORTATION ENTRY AND MANIFEST OF

“ GOODS SUBJECT TO CBP INSPECTION
Ni
— AND: PERNT Class of Entry »
LS Customs and Border Prarserion Pk Tr “et
Boo
Pas Piast (5 5 Pees .
Date. cae Na 4909 oftente, 49909-SAN JUANL..PR,
Pool 4999-SAN JUAN, PR One O4L4 212024

fentered or imported by L_LEZRAPTS. INCORPORAT. STREET B. LOT. NO 21 CPR ARS # GE = np O2SZIZ4 00 ts be shipped OM TRANSPORT INC ~ 66-076733400

in bond via ca
is TW T Newer TORTS, TOS tetioes oo ea Rare taal

consigned te

CBP Port Director 4909-SAN JUAN, P
Consiynee _ WILHELMSEN SHIPS SERVICE ; P

Foreign port of lading _ 42305- ANTWERP ANVERS.BEBGUL ULAR Date of sailing GLZI8/2024

te rE - 2 i} on 28 ET
ingoredon he GERHARD SCHUMTE = 2085 cr Fmt HONGKONG. dail

T
exponet fiom __BELGI "-Qapyalzora om Goode naw a "saa, auaagna Deb S38

Marks and Numbers | OFSCRIPTION AND QUANTITY OF MERCHANDISE | GROSS WEIGHT | VALUE ang oEPeckages _ uM BER. 0) KIND OF PACKAGES MTN POUNDS — | (Doilas Only) RATE DUTY y a per wnsies AS ADDR SSPKG CON 15451, 1,1-TRIFLO (HEC 3549 8910 AS ADDR 8PKG OTH, 20%>MASS TETRAFL (HFC 1429 3102 AS ADDR 13PKG OTH,30%>MASS TETRAFL (HFC 1631 4385 AS ADDR 13PKG FLUORINATED HYDROCARBN, HF 1753 4259

MERCHANDISE DETAINED BY EPA
UNDER ENTRY NO.DS400821467
TO BE EXPORTED UNDER CUSTOMS SHPERVISION
BOOKING : 63944973

M/V MAIRA 2415S
QP01170325013 Cont #/HEXY [it 64/26

ND | cP Set» ses

ie ond Authorized **

G.O. No O Check if withdrawn for Vesse} supplics (19 U.S.0.1309)

CERTIFICA, q

i id ca EVs, A ANRESATION! iN BOND worree tay Rory arm ones suremet ue re “il mab reat, re lg aad 4209- SAN. uan cast Entered or wethdiiban by Hf WITH THE EXCEPTIONS NOTED ABOVE , THE WITHIN - DESCRIBED GOODS WERE : Su Laden on the - Delivered to the Carrier ATTY... LN FACT HILDARIG RIVERA es aa ora eta to P Pol destination Cealed in CBP TV easch veda cr airerat To tlie Inspector: (he above-described youds shall be disposed of scais Nos. which cleared for - Mh Ss BEG 32, 1.0. i PUERTO) PANA AR ee ee
@ IC PACKERS Cwere} dyer ¢ ft 24 r :
HOU) Idbcleds ur corded net JO" 22 1p fake perl false Ui, bet i wi hee Te atnetent mi very seated. i/o thy ile rs, at she Ber Pa INBOND MOVEMENT [as verified by export records t ae cutie “hit el onde exeebt as Wwte Herexn 2TH! vA OM UPRANSPOR'S INC IRS#: 66-076733409

CSET

Tae Attomey or Agent oF Carrer
CBP Form 7512 (0212)

PAGE # 0002

REF #: 452991 LOG #
CO SE.B Na, 1656-0005
Pee ae te TRANSPORTATION ENTRY AND MANIFEST OF [Toy gp 35 GOODS SUBJECT TO CBP INSPECTION ane Aaa. ae AND PERMIT . mh
. LES Custems aad Border Prokecune 2 t Biew Back. ot
bate Tian 4909-SAN JUAN, PR

-S Date £

Part of 4909-SAN JOAN PR mene AE LIZLAI2S
Eniured or imported by, Y OR ey BET iam. Z Age /RS # 6603521 240Q_ tone shipped

OM TRANSPORT INC - 66-076733400

eoasiyned (9

wt bond via
TORN ATTEN

TAT RRS SRR TE

inal foreign destination

CBP Port Director 49909~SAN JEAN
Consignce LHE. Ei

Foreiga port of lading S£2305-ANTWERE ANY ERS BELGu Dore of sailing QL/A TE /2023 TRE Taam he Be Tents “Sarees tet : deed ces

Exported from ~—~BELGIUM on OL 18/2029 Goods now at N744-ALMACENES DEL CAST 1 Wate t f use, ie ee

Ceuny T

——— a Sd
Marks and Numbers | DESCRIPTION AND QUANTITY OF MERCHANDISE | GROSS WEIGHT VALUE F of Packages NUM DER AN v0 % CRAGES aN POUNDS (Dottars Only) RATE oUTY ETD: 04/25/2004 Cont # dexitb4ee ip Leal & MSSUSETH wag Be US
— Inbond Authorized
TOTALS : 8362 20656 200
G.0. No Check if withdrawn for Vessel supplies (19 U.8.C. 1309) CERTIFICATE SEE FORTATION IN BOND coreg ly PECTS Thay th ney Parca eas Ponte Tera Bre this She wi 2D9- SEN JUBN, PR. Entered or iit by WITH THE EXCEPTIONS NOTED ABOV THE IN ~ DESCRIBED GOODS WERE: ——— JOR I PE ES Laden on the - Delivered to the Carrier ATTY. IN FACT. HID Cc named above, for delivery to the CBP Port Director at destination sealed with CBP Uta Mah 08 ite To the Inspactor: The above-described goods ghall be disposed of scals Nos, which cleared for -

MANZANILLO, (PUERTO)

ar ie es Were) Were a17 Fr Recgped ia the Treelar | Y
nol ) tenors corded and fo" Qa 184202 s rehondise thesstihe ti ed ne ‘ ort tn spar alton anid detivery sualed je Clista users al her smith) he Ove INBOND MOVEMENT | 4s verified by export records mcKoRS wh apparent ood sabe eee AS BON He AUTHORIZED ars OM TRANSPORT ING IRSH: 66-0767334600 TTset TET Attorney oc Agent of Carner

GABP Rare S02 ( 03412}

CERTIFICATE OF SERVICE

I certify that copies of the foregoing “Expedited Settlement Agreement/Consent Agreement” and “Final Order,” in the matter of Liferafts Incorporated of P.R., Docket No. CAA- 2024-8452, were sent to the following persons in the manner indicated:

By E-mail:

Ethan Thompson

Attorney-Advisor

United States Environmental Protection Agency
Air Enforcement Division
[email protected]

Charles Ortiz

Comptroller/HSSE & QA Director
Liferafts Incorporated of Puerto Rico
[email protected]

Ricardo Guzman-Lopez de Victoria
Attorney for Respondent
[email protected]

Dated: Jul 12, 2024 CR L,; Cr

Emilio Cortes
Clerk of the Board