Wego Chemical Group, LP (Board decision, December 5, 2025)

Read the official release (epa.gov)

Plain-English summary

Wego Chemical Group, LP imports hydrofluorocarbons. EPA alleged that Wego failed to submit advance notification reports on time for the shipments listed in the settlement attachment. The agreement identifies five late advance reports and five failures to provide advance reporting, and sets a $15,000 civil penalty. Wego completed and submitted all reports as corrective action, waived its rights to contest the allegations and appeal, and agreed to comply with the Final Order. The EAB ratified the settlement.

Decision snapshot

• Cited authorities: American Innovation and Manufacturing Act, 42 U.S.C. §§ 7413 and 7675, and 40 C.F.R. parts 13, 19, 22, and 84
• Outcome: The Expedited Settlement Agreement was ratified, Wego was ordered to comply with its terms, and a $15,000 civil penalty was approved.
• Key point: HFC importers must submit advance notification reports within the applicable regulatory deadlines.

Full text (EPA EAB public release)

F I L E D
Dec 05, 2025
Clerk, Environmental Appeals Board
ENVIRONMENTAL APPEALS BOARD INITIALS ______
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.

                                           )
                                           )

In re Wego Chemical Group, LP ) Docket No. CAA-2026-8721
)
)
)
)

                                 FINAL ORDER


                             Decided December 5, 2025



  Before Environmental Appeals Judges Aaron P. Avila and Ammie Roseman-Orr

  Order of the Board by Judge Avila:

  Pursuant to 40 C.F.R. § 22.18(b)-(c) of EPA’s Consolidated Rules of Practice

Governing the Administrative Assessment of Penalties and the Revocation/Termination or Suspension of Permits, the attached Expedited Settlement 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, effective immediately.
So ordered.

ENCLOSURE 1
EXPEDITED SETTLEMENT AGREEMENT
ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
)
In re: )
) Docket No. CAA-2026-8721
Wego Chemical Group, LP )
)
)
a)
EXPEDITED SETTLEMENT AGREEMENT
A. JURISDICTION

1. This is an expedited administrative penalty assessment proceeding brought for alleged
   violations of the American Innovation in Manufacturing Act of 2020 (“AIM Act”), 42 U.S.C.
   § 7675, which governs the import of hydrofluorocarbons (“HFCs”), under Section 113(d) of the Clean Air Act (“CAA”), 42 U.S.C. § 7413(d), which authorizes the United States Environmental Protection Agency (“EPA”) to bring administrative civil enforcement actions.

2. This expedited settlement agreement (“Agreement”) is entered into under Section 113(d) of
   the CAA, 42 U.S.C. § 7413(d), and the Consolidated Rules of Practice Governing the Administrative Assessment of Penalties and the Revocation/Termination or Suspension of Permits, 40 C.F.R. Part 22.

3. Complainant is the United States Environmental Protection Agency. On the EPA’s behalf,
   Acting Director Sparsh S. Khandeshi, Air Enforcement Division, is delegated the authority to settle civil administrative penalty proceedings under Section 113(d) of the CAA.

4. Respondent is Wego Chemical Group, LP (“Wego”) and is a “person” as defined below and
   identified further in Table 1 of the Expedited Settlement Agreement (“ESA”) Attachment 1.

5. Complainant and Respondent (together, the “Parties”), having agreed that settlement of this
   action is in their mutual interest, consent to the issuance of the attached final order (“Final Order” or “Order”) ratifying this expedited settlement 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. Furthermore, Complainant has determined, and Respondent does not dispute, that settlement of this action is in the public interest.

6. The EPA and the United States Department of Justice jointly determined that this matter,
   although it involves alleged violations that occurred more than one year before the initiation of this proceeding, is appropriate for an administrative penalty assessment. 42 U.S.C.

§ 7413(d).

7. 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)(1) and 22.18(b).

8. 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

9. This proceeding arises under the AIM Act, 42 U.S.C. § 7675, and Section 113 of the CAA,
   42 U.S.C. § 7413, and the regulations promulgated thereunder, which impose limits on HFC production and consumption.

10. The EPA is authorized to enforce the AIM Act and any regulation promulgated thereunder
    utilizing the federal enforcement authorities established by Section 113 of the CAA, 42 U.S.C. § 7675(k)(1)(C). Section 113 of the CAA authorizes the Administrator of the EPA to assess a civil administrative penalty of not more than $25,000 per day of violation. 42 U.S.C.
    § 7413(a)(3)(A), (d)(1). Pursuant to the Federal Civil Penalties Inflation Adjustment Act of 1990, Pub. L. 101-410, as amended, and its implementing regulation, the Civil Monetary Penalty Inflation Adjustment Rule, codified at 40 C.F.R. Part 19, the statutory maximum civil administrative penalty has subsequently been raised to $59,114 per day of violation. 40 C.F.R. § 19.4, Table 1.

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

12. The regulations at 40 C.F.R. Part 84, Subpart A, apply to any person who imports a regulated
    substance. 40 C.F.R. § 84.1(b).

13. 40 C.F.R. § 84.5(b)(1) states that “[n]o person may import bulk regulated substances, either
    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 for 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 present as a single component or a multicomponent blend.”

14. Pursuant to 40 C.F.R. § 84.31(a), “any person who ... imports, ... regulated substances”
    must comply with specified reporting requirements.

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15. The regulations at 40 C.F.R. § 84.31(c)(7) provide that the importer of record of imported
    regulated substances must submit an advance notification report for each shipment of regulated substances imported no later than 10 days prior to the date of importation if arriving by marine vessel and no later than 5 days if arriving by non-marine vessel.

16. The definitions, listed at 40 C.F.R. Part 84, Subpart A, include:

a) An “allowance” is defined as a “limited authorization for the production or consumption of a regulated substance established under subsection (e) of Section 103 in Division S, Innovation for the Environment, of the Consolidated Appropriations Act, 2021 (Pub. L. 116-260) (the AIM Act). An allowance allocated under subsection (e) of Section 103 in Division S of the AIM Act does not constitute a property right.” 40 C.F.R. § 84.3.

b) “Bulk” is defined as “a regulated substance of any amount that is in a container for the transportation or storage of that substance such as cylinders, drums, ISO tanks, and small cans. A regulated substance that must first be transferred from a container to another container, vessel, or piece of equipment in order to realize its intended use is a bulk substance. A regulated substance contained in a manufactured product such as an appliance, an aerosol can, or a foam is not a bulk substance.” 40 C.F.R. § 84.3.

c) “Consumption allowances” are “a limited authorization to produce and import regulated substances; however, consumption allowances may be used to produce regulated substances only in conjunction with production allowances.” 40 C.F.R. § 84.3.

d) “Exchange value” is defined as the “value assigned to a regulated substance in accordance with AIM Act subsections (c) and (e), as applicable, and as provided in Appendix A to 40 C.F.R. Part 84.” 40 C.F.R. § 84.3.

e) “Exchange value equivalent” is defined as “the exchange value-weighted amount of a regulated substance obtained by multiplying the mass of a regulated substance by the exchange value of that substance.” 40 C.F.R. § 84.3.

f) “Import” is defined as “to land on, bring into, or introduce into, or attempt to land on, bring into, or introduce into, any place subject to the jurisdiction of the United States, regardless of whether that landing, bringing, or introduction constitutes an importation within the meaning of the customs laws of the United States. Offloading used regulated substances recovered from equipment aboard a marine vessel, aircraft, or other aerospace vehicle during servicing is not considered an import.” 40 C.F.R. § 84.3.

g) “Importer” is defined as “any person who imports a regulated substance into the United States. ‘Importer’ includes the person primarily liable for the payment of any duties on the merchandise or an authorized agent acting on his or her behalf. The term also includes: (1) [t]he consignee; (2) [t]he importer of record; (3) [t]he actual owner; or (4)
[t]he transferee, if the right to draw merchandise in a bonded warehouse has been transferred.” 40 C.F.R. § 84.3.

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h) “Person” is defined as “any individual or legal entity, including an individual, corporation, partnership, association; state, municipality, political subdivision of a state, Indian tribe; any agency, department, or instrumentality of the United States; and any officer, agent, or employee thereof.” 40 C.F.R. § 84.3.

i) “Regulated substance” is defined as “a hydrofluorocarbon listed in the table contained in subsection (c)(1) of the AIM Act and a substance included as a regulated substance by the Administrator under the authority granted in subsection (c)(3).” 40 C.F.R. § 84.3.

17. A current list of regulated substances, their chemical formulas, and their exchange values can
    be found in Appendix A to 40 C.F.R. Part 84. See 40 C.F.R. § 84.3.

18. The regulated substances at issue in this matter are assigned the following exchange values:

Chemical Formula or Blends Exchange Value

HFC-152a CH3 CHF2 124
HFC-245fa CHF2 CH2 CF3 1030
40 C.F.R. Part 84, Appendix A.
C. ALLEGED VIOLATION(S) OF LAW

19. The EPA alleges Respondent, the importer of record, violated 40 C.F.R. § 84.31(c)(7) by
    failing to timely submit advance notification reports for the shipments of regulated substances identified in Tables 1a and 1b of ESA Attachment 1 no later than 10 days prior to the date of importation.

D. TERMS OF AGREEMENT

20. 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 Tables 1a and 1b 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 violation(s) of law set forth in Section C of this Agreement; and

e. waives its right to appeal the Final Order accompanying this Agreement.

21. By signing this Agreement, respondent waives any rights or defenses that respondent has or
    may have for this matter to be resolved in federal court, including but not limited to any right to a jury trial, and waives any right to challenge the lawfulness of the final order accompanying the expedited settlement agreement.

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22. 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;

d. waives its right to request a hearing, any right to contest the allegations in this Expedited Settlement Agreement and Final Order and its right to appeal this Expedited Settlement Agreement and Final Order;

e. consents to personal jurisdiction in any action to enforce this Agreement or Final Order, or both, in an appropriate United States District Court; 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 an appropriate United States District Court to compel compliance with the Agreement or Final Order, or both, and to seek an additional penalty for noncompliance with the Agreement or Final Order and agrees that federal law shall govern in any such civil action.

E. TERMS OF PAYMENT

23. Respondent agrees to pay a civil penalty in the amount of $15,000 (“Assessed Penalty”),
    which is stated in Table 3 of ESA Attachment 1, within thirty (30) calendar days after the date the Final Order ratifying this Agreement is filed with the Clerk of the Environmental Appeals Board (“Filing Date”). Respondent shall pay the Assessed Penalty and any interest, fees, and other charges due using any method, or combination of appropriate methods, as provided on the EPA website: https://www.epa.gov/financial/makepayment. For additional instructions see: https://www.epa.gov/financial/additional-instructions-making-payments- epa. However, for any payments made after September 30, 2025, and in accordance with the March 25, 2025 Executive Order on Modernizing Payments To and From America’s Bank Account, Respondent shall pay using one of the electronic payments methods listed on the EPA’s How to Make a Payment website and will not pay with a paper check.

24. When making a payment, Respondent shall:

a. Identify every payment with Respondent’s name and the docket number of this Agreement, CAA-2026-8721,

b. Concurrently with any payment or within 24 hours of any payment, Respondent shall serve proof of such payment (electronic correspondence is preferred) to the following persons:

Tommie Madison, Clerk of the Environmental Appeals Board 5

U.S. Environmental Protection Agency, Headquarters

1200 Pennsylvania Avenue, NW

Mail Code 1103M

Washington, DC 20460-0001

Clerk [email protected]

Conner Kingsley, Attorney Advisor

U.S. Environmental Protection Agency, Headquarters

2.2226 J, William Jefferson Clinton Building South

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

Mail Code 2242A

[email protected]

U.S. Environmental Protection Agency

Cincinnati Finance Center

Via electronic mail to:

[email protected]

“Proof of payment” means, as applicable, a copy of the check, confirmation of credit card or debit card payment, or confirmation of wire or automated clearinghouse transfer, and any other information required to demonstrate that payment has been made according to EPA requirements, in the amount due, and identified with the appropriate docket number and Respondent’s name.

25. Interest, Charges, and Penalties on Late Payments. Pursuant to 42 U.S.C. § 7413(d)(5), 31
    U.S.C. § 3717, 31 C.F.R. § 901.9, and 40 C.F.R. § 13.11, if Respondent fails to timely pay any portion of the Assessed Penalty per this Agreement, the entire unpaid balance of the Assessed Penalty and all accrued interest shall become immediately due and owing, and the EPA is authorized to recover the following amounts.

a. Interest. Interest begins to accrue from the Filing Date. If the Assessed Penalty is paid in full within thirty (30) days, interest accrued is waived. If the Assessed Penalty is not paid in full within thirty (30) days, interest will continue to accrue until any unpaid portion of the Assessed Penalty as well as any interest, penalties, and other charges are paid in full. Per 42 U.S.C. § 7524(c)(6), interest will be assessed pursuant to 26 U.S.C. § 6621(a)(2), that is the IRS standard underpayment rate, equal to the Federal short-term rate plus 3 percentage points.

b. Handling Charges. The United States’ enforcement expenses including, but not limited to, attorneys’ fees and costs of handling collection.

c. Late Payment Penalty. A ten percent (10%) quarterly non-payment penalty.

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26. Late Penalty Actions. In addition to the amounts described in the prior Paragraph, if
    Respondent fails to timely pay any portion of the Assessed Penalty per this Agreement, the EPA may take additional actions. Such actions the EPA may take include, but are not limited to, the following.

a. Refer the debt to a credit reporting agency or a collection agency, pursuant to 40

C.F.R. §§ 13.13 and 13.14.

b. Collect the debt by administrative offset (i.e., the withholding of money payable by the United States government to, or held by the United States government for, a person to satisfy the debt the person owes the United States government), which includes, but is not limited to, referral to the Internal Revenue Service for offset against income tax refunds, pursuant to 40 C.F.R. Part 13, Subparts C and H.

c. Suspend or revoke Respondent’s licenses or other privileges, or suspend or disqualify Respondent from doing business with the EPA or engaging in programs the EPA sponsors or funds, pursuant to 40 C.F.R. § 13.17.

d. Request that the Attorney General bring a civil action in the appropriate district court to enforce the Final Order and recover the full remaining balance of the Assessed Penalty, in addition to interest and the amounts described above, pursuant to 42 U.S.C. § 7413(d)(5). In any such action, the validity, amount, and appropriateness of the Assessed Penalty and Final Order shall not be subject to review.

27. Allocation of Payments. Pursuant to 31 C.F.R. § 901.9(f) and 40 C.F.R. § 13.11(d), a partial
    payment of debt will be applied first to outstanding handling charges, second to late penalty charges, third to accrued interest, and last to the principal that is the outstanding Assessed Penalty amount.

28. Tax Treatment of Penalties. Pursuant to 26 U.S.C. § 162(f), penalties, interest, and other
    charges paid pursuant to this Agreement shall not be deductible for purposes of federal taxes.

29. 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.

30. 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.

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31. 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.

32. 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 electronic mail. Respondent understands that the mailing or e-mail address may be made public when the Agreement and Certificate of Service are filed and uploaded to a searchable database. Complainant agrees to acceptance of the Respondent’s digital or an original signature on this Agreement.

33. Each party shall bear its own attorney’s fees, costs, and disbursements incurred in this
    proceeding.

F. EFFECT OF AGREEMENT AND ATTACHED FINAL ORDER

34. 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.

35. 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.

36. 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.

37. Any violation of this Agreement or Order may result in a civil judicial action for an
    injunction, or civil penalties of up to $124,426 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 Agreement in an administrative, civil judicial, or criminal action.

38. 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.

39. 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.

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40. 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.

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Respondent and Complainant agree to the Environmental Appeals Board issuance of the

attached Final Order ratifying the Agreement.

The foregoing Agreement In the Matter of Wego Chemical Group, LP, Docket No. CAA-

2026-8721 is Hereby Stipulated, Agreed, and Approved.

COMPLAINANT:

[digital signature]

Signature

Sparsh S. Khandeshi, Acting Director

Air Enforcement Division

Office of Civil Enforcement

Office of Enforcement and Compliance Assurance

U.S. Environmental Protection Agency

10

The foregoing Agreement In the Matter of Wego Chemical Group, LP, Docket No. CAA-2026-

8721, is Hereby Stipulated, Agreed, and Approved.

FOR RESPONDENT:

.

[signature]

October 15, 2025

Signature

Date

Printed Name:

Julia Hanft

Title:

General Counsel

Address:

277 Northern Blvd., Great Neck, NY 11021

Federal Tax Identification Number:

84-4986638

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EXPEDITED SETTLEMENT AGREEMENT ATTACHMENT 1

AMERICAN INNOVATION AND MANUFACTURING ACT

OFFSITE COMPLIANCE MONITORING ACTIVITY OR INSPECTION FACTS,

ALLEGED VIOLATIONS, PENALTY, AND CORRECTIVE ACTION FORM

Table 1a — Offsite Compliance Monitoring Activity or Inspection Stipulated Facts

Docket Number: CAA-2026-8721

Offsite Compliance Monitoring Activity

Date: 9/16/2025

Person/Importer Name (“Respondent”) and

Port of Entry/Shipment Numbers: See

below

Importer Number: Wego Chemical Group,

LP 47-565494500

Respondent Address: 239 Great Neck Rd,

Inspector Name and Email Address:

Great Neck, New York 11021

Charlotte Papp; [email protected]

Subject Regulated Substances: See below

Arrival Date: See below

Table 1b — Summary of Regulated Substance Shipments

Importation | Advance

Entry

HFC/HFC | Mode of

Days

Date!

Notification | Number

Blend

Transportation

Advance

Notification

Report

Filing Date

Reports

Late

03/17/2024

03/15/2024

B2Y80064492

HFC-152a

Marine Vessel

8

04/18/2024

04/19/2024

B2Y80066042

HFC-152a

Marine Vessel

11

04/18/2024

04/19/2024

B2Y80066034

HFC-152a

Marine Vessel

11

06/17/2024

06/22/2024

B2Y80068006

HFC-245fa

Marine Vessel

15

07/13/2024

07/11/2024

B2Y80068345

HFC-245fa

Marine Vessel

8

08/26/2024

08/29/2024

B2Y80069293

HFC-245fa

Marine Vessel

13

08/29/2024

08/22/2024

B2Y80069160

HFC-152a

Marine Vessel

3

08/29/2024

08/22/2024

B2Y80069152

HFC-152a

Marine Vessel

3

08/30/2024

09/06/2024

B2Y80069392

HFC-152a

Marine Vessel

17

01/14/2025

01/06/2025

B2Y80069970

HFC-152a

Marine Vessel

a

! This is the "Arrival Date” per the Customs and Border Protection (“CBP”) Government Client Manifest Capability

(“GCMC”) Entry Summary.

Table 2 — Description of Alleged Violations

The EPA alleges that:

the importer of record failed to timely submit advance notification reports for the

import of regulated substances no later than 10 days if arriving by marine vessel or 5

days for non-marine vessel prior to the date of importation, in violation of

40 C.F.R. § 84.31(c)(7), for the entries listed in Tables 1a and 1b.

Table 3 — Civil Penalty

Complainant and Respondent agree upon the following civil penalty for settlement

purposes: $15,000, based on the formula below.

Number of Violations * Violation Type Penalty Amount = Penalty

5 * $1,000 (Late advance reporting) + 5 * $2,000 (Failure to provide any advance reporting”) =

$15,000

Violation Type

Total

Penalty

Amount

Late advance reporting (40 C.F.R. § 84.31(c)(7))

$1,000

Failure to provide any advance reporting (40 C.F.R. § 84.31(c)(7))

$2,000

Late quarterly reports (40 C.F.R. § 84.31(c)(1))

$2,500

Incomplete or inaccurate quarterly reporting (40 C.F.R. § 84.31(c)(1))

$3,000

Failure to submit quarterly reports (40 C.F.R. § 84.31(c)(1))

$3,500

Late annual reports (40 C.F.R. § 84.33(a): 40 C.F.R. § 84.60(a))

$10,000

Incomplete or inaccurate annual reporting (40 C.F.R. § 84.33(a); 40

$10,000

C.F.R. § 84.60(a))

Failure to submit annual reports (40 C.F.R. § 84.33(a); 40 C.F.R. §

$15,000

84.60(a))

Failure to maintain records (40 C.F.R. § 98.3(g))

$5,000

Late annual GHG reports (40 C.F.R. § 98.3(b))

$10,000

Incomplete or inaccurate annual GHG reporting (40 C.F.R. § 98.3(b)

3

.

$10,000

40 C.F.R. § 98.3(h))

Failure to submit annual GHG reports (40 C.F.R. § 98.3(b))

$15,000

? Where an importer submits a report after the date of importation, the EPA considers the importer to have failed to

submit an advance import report under 40 C.F.R. § 84.31(c)(7).

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HFC EV³ Percentage Multiplier
< 1,300 20%
≥ 1,300 ≤ 5,000 30%

5,000 ≤ 10,000 40%
10,000 ≤ 15,000 50%

TT Product GWP⁴ Percentage Multiplier
< 1,300 20%
≥ 1,300 ≤ 5,000 30%

5,000 ≤ 10,000 40%
10,000 ≤ 15,000 50%

HFC EV
HFC-152 53
HFC-41 92
HFC-152a 124
HFC-143 353
HFC-32 675
HFC-245ca 693
HFC-365mfc 794
HFC-245fa 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
HFC-143a 4,470
HFC-236fa 9,810
HFC-23 14,800

ODS Percentage Multiplier
Any ODS listed as a class I or class II controlled substance in 40 C.F.R. Part 82, whether on its own or in a blend 40%

Table 4 — Corrective Action

Respondent has completed and submitted all reports to EPA.

³ EVs are found in Appendix A of 40 C.F.R. Part 84.
⁴ Id.

CERTIFICATE OF SERVICE

    I certify that copies of the foregoing “Expedited Settlement Agreement” and “Final

Order” in the matter of Wego Chemical Group, LP, Docket No. CAA-2026-8721, were sent to the following persons on December 5, 2025 in the manner indicated:

By E-mail:

Conner Kingsley, Attorney Advisor Julia Hanft, General Counsel Air Enforcement Division Wego Chemical Group, LP William Jefferson Clinton Building South 277 Northern Blvd 1200 Pennsylvania Avenue, N.W. Great Neck, New York, 11021 Mail Code 2242A [email protected] Washington, DC 20460 [email protected]

                                                                    Digitally signed by
                                                                    TOMMIE MADISON
                                                                    Date: 2025.12.05
                                                                    08:55:27 -05'00'
                                                         Tommie Madison
                                                         Clerk of the Board