Bedoukian Research Inc. (Board decision, February 6, 2025)
In re Bedoukian Research Inc. (EAB TSCA Appeal No. 25-02C and EPCRA Appeal No. 25-01C): chemical reporting and new substance settlement approved
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Plain-English summary
Bedoukian Research Inc. operated a chemical facility in Danbury, Connecticut. EPA alleged that the company submitted incomplete or inaccurate EPCRA chemical release reports for methanol, formic acid, and n-hexane, and manufactured or imported five confidential chemical substances without the required TSCA notices or applications. The Consent Agreement requires an environmental management system and compliance audits, resolves the matter without adjudicating the facts or law, and provides for a $671,899 civil penalty after EPA remitted $200,000 of the larger gravity-based penalty. The Board ratified the agreement.
Decision snapshot
- Cited authorities: EPCRA Section 313 and TSCA Sections 5, 13, 15, and 16, with implementing regulations in 40 C.F.R. parts 13, 19, 22, 372, 720, and 723
- Outcome: The Consent Agreement was ratified, Bedoukian was ordered to complete the settlement conditions, and a $671,899 civil penalty was approved.
- Key point: Chemical manufacturers and importers must accurately report covered toxic-chemical activity and comply with TSCA notice requirements for new chemical substances.
Full text (EPA EAB public release)
F I L E D
Feb 06, 2025
Clerk, Environmental Appeals Board
ENVIRONMENTAL APPEALS BOARD INITIALS ________________________
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
)
)
In re Bedoukian Research Inc. ) Docket Nos. TSCA-HQ-2024-5006 &
) EPCRA-HQ-2024-5006
)
)
)
FINAL ORDER
Pursuant to 40 C.F.R. § 22.18(b)-(c) of EPA’s Consolidated Rules of Practice, the
attached 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.1
ENVIRONMENTAL APPEALS BOARD
Dated: February 6, 2025__ ______
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.
Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006
BEFORE THE ENVIRONMENTAL APPEALS BOARD UNITED
STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
)
IN THE MATTER OF )
)
Bedoukian Research Inc. )
Danbury, CT )
) Docket Nos. TSCA-HQ-2024-5006
) EPCRA-HQ-2024-5006
)
)
Respondent )
______)
CONSENT AGREEMENT
Complainant, United States Environmental Protection Agency
Bedoukian Research Inc. ( Bedoukian )
(collectively, the Partie ), hereby enter into this Consent Agreement and proposed Final Order before the taking of any testimony and without adjudicating of any issues of law or fact, consent to the terms of this Consent Agreement and attached Final Order .
I. PRELIMINARY STATEMENT
-
This civil administrative proceeding for the assessment of penalties pursuant to Section 325(c)
of the Emergency Planning and Community Right-to-Know- § 11045(c), and S as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act, Pub. L. No. 114-182, June 22, 2016, 130 Stat 448 (2016 Act) is being simultaneously commenced and concluded pursuant to Rules 22.13(b), 22.18(b)(2), and 22.18(b)(3) of the Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties, and the Revocation/Termination or Suspension of Perm
§§ 22.13(b), 22.18(b)(2), and (b)(3). -
To avoid the disruption of orderly business activities and the expense of protracted and costly
litigation, Respondent, for purposes of this proceeding only and as required by 40 C.F.R.
§ 22.18(b)(2):a. admits the following jurisdictional allegations and waives any defenses to
jurisdiction;1Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006b. neither admits nor denies the specific factual allegations contained herein; c. consents to the assessment of a civil penalty on the terms discussed below; d. consents to any conditions specified in this Consent Agreement; e. waives any right to contest the alleged violations of law set forth herein; and f. waives the rights to appeal the proposed Final Order accompanying this Consent Agreement. II. STATUTORY AND REGULATORY FRAMEWORK EPCRA -
Section 313(a) and (b) of EPCRA, 42 U.S.C. § 11023(a) and (b), and 40 C.F.R. §§ 372.22
and 372.30, provide that the owner or operator of a facility that (i) has ten or more full-time employees, (ii) is in Standard Industrial Classification (SIC) or North American Industry Classification System (NAICS) code as set forth in 40 C.F.R. § 372.23, and (iii) manufactured, processed, or otherwise used one or more toxic chemicals, listed under Section 313(f) of EPCRA and 40 C.F.R. §§ 372.28 and 372.65, above their reporting threshold must submit to EPA and the state in which the facility is located a chemical release form published under Section 313(g) of EPCRA for each such toxic chemical. -
Pursuant to Sections 313 and 328 of EPCRA, 42 U.S.C. §§ 11023 and 11048, EPA
promulgated regulations setting forth requirements for the submission of information relating to the release of toxic chemicals under Section 313. These regulations, as amended, are presently codified at 40 C.F.R. Part 372. -
Section 329(7), 42 U.S.C. § 11049(7), means any individual,
trust, firm, joint stock company, corporation (including a government corporation),
partnership, association, state, municipality, commission, political subdivision of a state, or
interstate body. -
EPCRA Section 329(4), 42 U.S.C. § 11049(4), and 40 C.F.R. §
372.3 means all buildings, equipment, structures, and other stationary items which are
located on a single site or on contiguous or adjacent sites and which are owned or operated
by the same person (or by any person which controls, is controlled by, or under common
control with such person). A facility may contain more than one establishment. -
- -
time equivalent employment. A facility would calculate the number of full-time employees
by totaling the hours worked during the calendar year by all employees, including contract
employees, and dividing that total by 2,000 hours.
- -
-
Section 329(10) of EPCRA, 42 U.S.C. § 11049(10), and 40
2Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006C.F.R. § 372.3 means a chemical or chemical category listed in 40 C.F.R. § 372.65.
-
Process as defined by 40 C.F.R. § 372.3, means the preparation of a toxic chemical, after
its manufacture, for distribution in commerce: (1) in the same form or physical state as, or in
a different form or physical state from, that in which it was received by the person so
preparing the substance, or (2) as part of an article containing the toxic chemical. Process
also applies to the processing of a toxic chemical contained in a mixture or trade name
product.
10.
compound a toxic chemical. Manufacture also applies to a toxic chemical that is produced
coincidentally during the manufacture, processing, use, or disposal of another chemical or
mixture of chemicals, including a toxic chemical that is separated from that other chemical or
mixture of chemicals as a byproduct, and a toxic chemical that remains in that other chemical
or mixture of chemicals as an impurity.
11.
including a toxic chemical contained in a mixture or other trade name product or waste, that
c chemical
does not include disposal, stabilization (without subsequent distribution in commerce), or
treatment for destruction unless: (1) the toxic chemical that was disposed, stabilized, or
treated for destruction was received from off-site for the purposes of further waste
management; or (2) the toxic chemical that was disposed, stabilized, or treated for destruction
was manufactured as a result of waste management activities on materials received from off-
site for the purposes of further waste management activities. Relabeling or redistributing of
the toxic chemical where no repackaging of the toxic chemical occurs does not constitute
otherwise use or processing of the toxic chemical.
-
Pursuant to Section 313(f) of EPCRA, 42 U.S.C. § 11023(f) and 40 C.F.R. § 372.25, with
respect to a toxic chemical manufactured or processed, the toxic chemical reporting threshold
for the reporting form to be submitted on or before July 1 of the succeeding year is 25,000
pounds of the toxic chemical per year. -
Pursuant to Section 313(f) of EPCRA, 42 U.S.C. § 11023(f) and 40 C.F.R. § 372.25, with
respect to a toxic chemical otherwise used, the toxic chemical reporting threshold for the
reporting form to be submitted on or before July 1 of the succeeding year is 10,000 pounds of
the toxic chemical per year. -
Pursuant to Section 313(g) of EPCRA, 42 U.S.C. § 11023(g), EPA published a uniform
Toxic Chemical Release Inventory Form (hereinafter, referred to as a Form R ) for facilities
that are subject to the reporting requirements of Section 313. -
Section 313(a) and (b) of EPCRA, 42 U.S.C. § 11023(a) and (b), and 40 C.F.R. §§ 372.30(d)
and 372.27(d) provide that a complete and accurate reporting form for activities involving a
toxic chemical that occurred during a calendar year must be submitted on or before July 1 of3Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006
the next year.
-
With respect to activities involving a toxic chemical at a facility, when more than one
threshold applies to the activities, the owner or operator of the facility must report if it
exceeds any applicable threshold and must report on all activities at the facility involving the
chemical, as established at 40 C.F.R. § 372.25(c). -
Section 325(c) of EPCRA, 42 U.S.C. § 11045(c), authorizes EPA to assess a civil penalty of
up to $25,000 per day for each violation of Section 313 and its implementing regulations.
The Debt Collection Improvement Act of 1996, 31 U.S.C. § 3701, as amended, and the
Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, 28 U.S.C. §
2461, and implementing regulations at 40 C.F.R. Part 19, increased these statutory maximum
penalties to $69,733 per day per violation for violations that occurred after November 2,
2015, where penalties are assessed on or after December 27, 2023.TSCA -
Section 5(a)(l) of TSCA, 15 U.S.C. § 2604(a)(l), and 40 C.F.R. §§ 720.22(a)(1) and 720.40(b),
provide that no person may manufacture (import) a new chemical substance unless such person
least ninety (90) calendar days before
manufacturing that substance. -
Section 5(h)(4) of TSCA, 15 U.S.C. § 2604(h)(4), provides that EPA may exempt the
manufacture of certain new chemicals from all or part of the full PMN requirements. -
PREMANUFACTURE NOTIFICATION EXEMPTIONS under 40 C.F.R. Part 723 were
promulgated under the authority of S
Section 5(h)(4) of TSCA, 15
U.S.C. § 2604(h)(4). Forty C.F.R. § 723.50 addresses chemical substances manufactured in
quantities of 10,000 kilograms or less per year, and/or chemical substances with low
environmental release and human exposure. -
Per the under 40 C.F.R. § 723.50(e)(1), an applicant must
submit to EPA an exemption application on EPA Form No. 7710-25 via CDX using e-PMN
software in the manner set forth in this paragraph at least thirty (30) days before the
manufacture of the new chemical substance begins. -
Per 40 C.F.R. § 723.50(j)(4), a person who manufactures a new chemical substance pursuant to
an LVE, a person must submit a new LVE notice before that person manufactures the chemical
substance subject to an LVE in an annual production volume above the volume designated by
the LVE. -
Section 13(a)(1)(B) of TSCA, 15 U.S.C. § 2612(a)(1)(B), provides that the Treasury shall
entry in violation of a rule or order under Section 5, 15 U.S.C. § 2604. Pursuant to 40 C.F.R. §
4
Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006
707.20(b)(2)(i), importers must sign the following statement for each import of a chemical
all applicable rules or orders under TSCA and that I am not offering a chemical substance for
-
as defined by 40 C.F.R. § 720.3(x) means any natural person, firm, company,
corporation, joint-venture, partnership, sole proprietorship, association, or any other business
entity, any State or political subdivision thereof, any municipality, any interstate body, and any
department, agency or instrumentality of the Federal Government. -
Section 3(9) of TSCA, 15 U.S.C. § 2602(9) means to import into
the customs territory of the United States (as defined in general note 2 of the Harmonized Tariff
Schedules of the United States), produce, or manufacture. -
A hemical substance is defined by Section 3(2)(A) of TSCA, 15 U.S.C. § 2602(2)(A), as
ny organic or inorganic substance of a particular molecular identity -
Section 3(11) of TSCA, 15 U.S.C. § 2602(11) and 40
C.F.R. § 720.3(v) means any chemical substance which is not included in the chemical
substance list compiled and published under Section 8(b) of TSCA, 15 U.S.C. § 2607(b). -
Section 15 of TSCA, 15 U.S.C. § 2614, makes it a prohibited act for any person to fail or refuse
to comply with any requirement of TSCA or any rule promulgated, order issued, or consent
agreement entered into under this title. -
Section 16 of TSCA, 15 U.S.C. § 2615, authorizes EPA to assess a civil penalty up to $37,500
per day for each violation of Section 15 of TSCA, 15 U.S.C. § 2614. The Debt Collection
Improvement Act of 1996, 31 U.S.C. § 3701, as amended, and the Federal Civil Penalties
Inflation Adjustment Act Improvements Act of 2015, 28 U.S.C. § 2461, and implementing
regulations at 40 C.F.R. Part 19, increased these statutory maximum penalties to $48,512 per
day per violation for violations that occurred after November 2, 2015, where penalties are
assessed on or after December 27, 2023.III. STIPULATED FACTS -
Complainant hereby states and alleges that Respondent has violated Section 313 of EPRCA, 42
U.S.C. § 11023, and Section 15 of TSCA, 15 U.S.C. § 2614 and the federal regulations
promulgated thereunder. -
At all relevant times to this matter, Respondent was a corporation formed in the state of
Connecticut with its US headquarters located at 6 Commerce Drive, Danbury, Connecticut
06810, and wa EPCRA Section 329(7), 42 U.S.C. § 11049(7), and 405Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006C.F.R. §§ 710.3 and 720.3(x) and, as such, was subject to Section 313 of EPCRA, 42 U.S.C. §
11023, and TSCA, 15 U.S.C. § 2601 et seq. and the regulations promulgated thereunder. -
At all relevant times to this matter, Respondent owned, controlled and/or operated a facility
in Danbury, Connecticut. The Danbury facility buildings are located at 21 Finance Drive,
Danbury, CT 06810 and at 27 Augusta Drive Danbury, CT 06810 (hereinafter, referred to as
the Facility). As these buildings are adjacent to each other, they are as defined by
40 C.F.R. § 372.3 for TRI reporting purposes. -
For the reporting years 2018, 2019, 2020, and
respect to methanol, formic acid, and n-hexane, because it met the criteria in Sections 313(a)
and (b) of EPCRA, 42 U.S.C. §§ 11023(a) and (b), and 40 C.F.R. §§ 372.22 and 372.30 as
follows:a. The Facility had 10 or more employees during 2018, 2019, 2020, and 2021; b. The Facility was in a North American Industry Classification System (NAICS) code (specifically 325199, as set forth in 40 C.F.R. 372.23); and c. the Facility in amounts greater than 10,000 pounds, the relevant threshold given in 40 C.F.R. § 372.25. d. Facility in amounts greater than 25,000 pounds, the relevant threshold given in 40 C.F.R. § 372.25. e. Formic acid, otherwise used at the Facility in amounts greater than 10,000 pounds, the relevant threshold given in 40 C.F.R. § 372.25. f. N- the Facility in amounts greater than 10,000 pounds, the relevant threshold given in 40 C.F.R. § 372.25. -
At all times relevant to this matter, Respondent manufactured, imported, processed, or
distributed in commerce, five chemical substances identified as Chemicals A, B, C, D, and E 1
(collectively hereinafter referred to as the Chemical Substances) or mixtures containing these
chemicals, or in the past had manufactured, imported, processed, or distributed in commerce
the Chemical Substances or mixtures containing these Chemical Substances as those terms
are defined in Sections 3(2), (5), (9), (10), and (13) of TSCA, 15 U.S.C. § 2602(2), (5), (9),
(10), and (13) respectively, and 40 C.F.R. § 720.3(e), (i), (q), (u), and (aa).
1
Respondent has claimed the identity of Chemicals A, B, C, D, and E as TSCA confidential business information ( CBI ).
6
Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006
-
At all times relevant to this matter, each of the Chemical Substances we
as that term is defined in Section 3(11) of TSCA, 15 U.S.C. § 2602(11) and 40
C.F.R. § 720.3(v). -
Respondent received LVE application approvals for Chemicals A and B on December 16,
1993, and Chemical E on November 30, 1992. -
The annual production volume specified in the LVEs that were approved on December 16,
1993 and November 30, 1992 for Chemicals A, B, and E were each limited to 1,000
kilograms. -
On July 19, 2023, EPA representatives conducted an inspection pursuant to Section 11 of
TSCA, 15 U.S.C. § 2610, and Section 313 of EPCRA, 42 U.S.C. § 11023, of the Danbury,
Connecticut facility and requested records related to
Section 313 of EPCRA and Section 15 of TSCA.
39.
during those inspections (including through a review of documents).
- the
conditions described in Section V, the payment of the civil penalty described in Section VI,
and the terms of settlement described in Section VII of this CAFO.IV. EPCRA
Count 1 Failures to Accurately Report Methanol in Violation of Section 313(a) of EPCRA
-
Paragraphs 1-17 and 30-40 are incorporated here by reference.
-
During reporting years 2018, 2019, 2020, and 2021
term is defined in 40 C.F.R. § 372.3, over 10,000 pounds of methanol at the Facility. -
During the reporting years 2018, 2019, 2020, and 2021, Respondent also manufactured
methanol, although not in amounts that exceed the threshold for reporting manufactured
methanol. -
Respondent timely filed Form R for methanol for reporting years 2018, 2019, 2020, and
-
However, Respondent failed to submit a complete and correct Form R for each of those
reporting years in the following ways:a. For reporting years 2018, 2019, 2020, and 2021, Respondent failed to indicate in Section 3 of Form R, all activities and uses of methanol specifically, methanol manufactured for reporting years 2018, 2019, 2020, and 2021. 7Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006b. For reporting year 2019, Respondent failed to accurately report the quantities of
methanol waste managed or transferred off-site in Section 6.2 and quantities used
for energy recovery off-site 8.3 of Form R.
45. indicate all appropriate categories of chemical use (i.e., methanol
manufactured) and/or completely and accurately report quantities of methanol waste
managed or transferred for reporting years 2018, 2019, 2020 and 2021 constitute four
separate violations of Section 313(a) of EPCRA, 42 U.S.C. § 11023(a).
-
Count 2 Failures to Accurately Report Formic Acid in Violation of Section 313(a) of EPCRA
-
Paragraphs 1-17 and 30-40 are incorporated here by reference.
-
During reporting year 2018 otherwise used
C.F.R. § 372.3, over 10,000 pounds of formic acid at the Facility. -
During Reporting year 2018, Respondent also processed formic acid, although not in
amounts that exceed the threshold for reporting manufactured formic acid.
49.
C.F.R. § 372.3, over 25,000 pounds of formic acid at the Facility.
- Respondent timely filed Form R for formic acid for reporting years 2018, 2020, and 2021.
However, Respondent failed to submit a complete and correct Form R for each of those
reporting years in the following ways:a. For reporting year 2018, Respondent failed to indicate in Section 3 all activities and uses of formic acid specifically, formic acid processed in reporting year 2018. b. For reporting years 2020 and 2021, Respondent failed to accurately report the quantities of formic acid waste managed or transferred off-site in Sections 6.2 and 8.3 of the Form R.- identify all appropriate categories of use (i.e., formic acid processed)
and/or completely and accurately report quantities of waste managed or transferred off-site
for formic acid for reporting years 2018, 2020 and 2021, constitute three separate violations
of Section 313(a) of EPCRA, 42 U.S.C. § 11023(a).
- identify all appropriate categories of use (i.e., formic acid processed)
Count 3 Failures to Accurately Report n-Hexane in Violation of Section 313(a) of EPCRA
-
Paragraphs 1-17 and 30-40 are incorporated here by reference.
-
For reporting years 2018, 2020, and
defined in 40 C.F.R. § 372.3, over 10,000 pounds of n-hexane at the Facility. -
Respondent timely filed Form R for n-hexane for reporting years 2018, 2020, and 2021.
However, Respondent failed to submit a complete and correct Form R for each of those8Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006reporting years by failing to accurately report the quantities of n-hexane otherwise used in the
Sections 6.2 and 8.3 of Form R. -
of n-hexane waste
managed or transferred off-site in Section 6.2 and quantities used for energy recovery off-site
8.3 of Form R for reporting years 2018, 2020 and 2021, as set forth above, constitute three
separate violations of Section 313(a) of EPCRA, 42 U.S.C. § 11023(a).TSCA Count 4 Violations of Section 5(a)(1) of TSCA -
Paragraphs 1-2 and 18-40 are incorporated here by reference.
-
Between the calendar years 2018 and 2023, Respondent manufactured Chemical A at least 135
times, Chemical B at least 61 times, and Chemical E at least 41 times (with relevant dates and
quantities claimed as CBI) before submitting PMNs or new LVE applications for these
Chemicals. -
Respondent imported Chemical C between calendar years 2018 and 2022 at least 13 times, and
manufactured Chemical D between the calendar years 2018 and 2023 at least 75 times (with
relevant dates and quantities claimed as CBI) prior to submitting PMNs or LVE applications for
these Chemicals. -
Chemicals A, B, C, D, and E were not included on the TSCA Inventory at the time of
manufacture (import), and therefore, Section
3(11) of TSCA, 15 U.S.C. § 2602(11) and 40 C.F.R. § 720.3(v). -
or LVE applications at least ninety (90) days before
manufacturing (importing) Chemicals A, B, C, D, and E constitute failures to comply with
Section 5 of TSCA, 15 U.S.C. § 2604, which are prohibited acts under Section 15(1) of TSCA,
15 U.S.C. § 2614(1).Count 5 Violations of Section 13(a)(1)(B) of TSCA -
Paragraphs 1-2 and 18-40 are incorporated here by reference.
-
On August 17, 2023, Respondent informed EPA that it had imported Chemical C between
calendar years 2018 and 2022 at least 13 times (with relevant dates and quantities claimed as
CBI) prior to submitting a PMN or LVE application for this Chemical. -
Section 13 of TSCA prior to
importing Chemical C constitute failures to comply with Section 13 of TSCA, which are
prohibited acts under Section 15(3)(B) of TSCA, 15 U.S.C. § 2614(3)(B).9Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006V. CONDITIONS -
Respondent and EPA have agreed, in compromise of the civil penalty that otherwise may be
imposed herein, to the conditions of settlement described in Paragraphs 65-74.
Development, Implementation, and Evaluation of Environmental Management System
- Within 270 days of the Effective Date, Respondent will develop and implement a compliance
comprehensive EMS and contains an EMS implementation schedule for each of the described systems and subsystems not already fully implemented. The Environmental Management System Manual shall describe or contain, as appropriate, overarching policies, procedures, and programs that compose the facility-wide EMS framework, and respective management systems,
-Focused Environmental Management System-Enforcement Agreement
Guidance A; and 2) International Standards of
Requirements with guidance for use. In developing the EMS, Respondent will also review the following Areas of Concern detailed on page 14 of the September 19, 2023 TSCA Inspection Report for the Facility and incorporate them as appropriate into the EMS:
a. Chemicals manufactured, processed, or used under the TSCA research and
development exemption are used in accordance with 40 C.F.R. § 720.36(d); and
b. Isolated intermediates are manufactured in accordance Section 5 PMN requirements
under 40 C.F.R. § 720.22.
-
EMS Evaluation.
implementation of its EMS and consistent with Element 11 of the EPA EMS Guidance,
Respondent will conduct an evaluation of the EMS and translate assessment results into EMS
improvements . The EMS Evaluation will evaluate the adequacy of
EMS and EMS Manual and identify areas of concern from top management
down, throughout each major organizational unit and responsibilities under the EMS Manual.
The EMS Evaluation shall be conducted in accordance with ISO 19011, and shall determine the
following:a. Whether there is a defined system, subsystem, program, or planned task for the respective EMS element; b. To what extent the system, subsystem, program, or task has been implemented, and is being maintained; c. The adequacy of s internal self-assessment procedures for programs and tasks comprising the EMS; 10Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006d. Whether Respondent is effectively communicating environmental requirements to affected parts of the organization, or those working on behalf of the organization; e. Whether further improvements should be made to the EMS and EMS Manual to better conform with ISO 14001 and the EMS Guidance; f. Whether there are observed deviations from written requirements or procedures; and g. Whether continual improvement is occurring. -
EMS Evaluator.
assist Respondent in its evaluation of the EMS described in Paragraphs 65-66. The EMS
Evaluator will meet the following criteria:a. The EMS Evaluator will have experience in developing and implementing EMSes in accordance with ISO 14001:2015; b. The EMS Evaluator will have expertise and competence in Title I of TSCA and its implementing regulations; c. The EMS Evaluator and their personnel have not conducted research, development, design, construction, financial, engineering, legal, consulting, or other advisory services for the Respondent within three years prior to the Effective Date of this CAFO, except to the extent the EMS Evaluator or their personnel assisted Respondent in developing or implementing the EMS or EMS Manual as described in Paragraph 65. However, an EMS Evaluator with personnel who, before working for the EMS Evaluator, conducted research, development, design, construction, or consulting services for Respondent (as an employee or contractor) may meet the requirements of independence by ensuring that these personnel do not participate on, manage, or advise the EMS Evaluator with respect to any obligations under the CAFO that the EMS Evaluator is selected to perform. For each EMS Evaluator, Respondent must provide descriptions of any previous work contracts, or financial relationship that the EMS Evaluator has had with Respondent; d. The EMS Evaluator was not involved in developing or implementing programs and procedures for complying with TSCA or the regulations promulgated thereunder, except to the extent the EMS Evaluator or their personnel assisted Respondent in developing or implementing the EMS or EMS Manual as described in Paragraph 65; and e. Notwithstanding subparagraph (d) of this Paragraph, to the extent that the EMS Evaluator or their personnel assisted in the development or implementation of the EMS or EMS Manual, the specific personnel that assisted in the development or implementation of the EMS or EMS Manual will not be involved in the EMS Evaluation. However, personnel of the EMS Evaluator who did not assist in the 11Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006development or implementation of the EMS or EMS Manual are permitted to be involved in the EMS Evaluation. EMS Implementation: Facility Compliance Audit -
Facility Audit.
implementation of its EMS and consistent with Element 11 of the EPA EMS Guidance,
Respondent will retain at least one individual to serve as an independent auditor to conduct a
facility -
Qualifications of the Independent Auditor.
Respondent retains to complete the facility compliance audit referenced in Paragraph 68 will
meet the following criteria:a. The Facility Auditor shall have demonstrated experience and expertise in chemistry, chemical nomenclature used in the TSCA inventory, and the application of TSCA compliance assessments, including, but not limited to, Sections 4, 5, 6, 8, 12, 13, and 15 of TSCA and the regulations promulgated thereunder; b. The Facility Auditor and their personnel have not conducted research, development, design, construction, financial, engineering, legal, consulting, or other advisory services for the Respondent within three years prior to the Effective Date of this CAFO. However, a Facility Auditor with personnel who, before working for the Facility Auditor, conducted research, development, design, construction, or consulting services for Respondent (as an employee or contractor) may meet the requirements of independence by ensuring that these personnel do not participate on, manage, or advise the Facility Auditor with respect to any obligations under the CAFO that the Facility Auditor is selected to perform. For each Facility Auditor, Respondent must provide descriptions of any previous work contracts, or financial relationship that the Facility Auditor has had with Respondent; c. The Facility Auditor was not involved in developing or implementing programs and procedures for complying with TSCA or the regulations promulgated thereunder; d. The Facility Auditor is not evaluating any aspect of the design, engineering, or mechanical integrity he/she developed or implemented; and e. Notwithstanding subparagraphs (b)-(d) of this Paragraph, the Facility Auditor and the EMS Evaluator may be the same individual(s) and involve the same personnel, provided that these parties meet both the respective qualifications for serving as a Facility Auditor and EMS Evaluator as prescribed in this CAFO. 12Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006 -
Within 10 business days of selecting the Facility Auditor, Respondent shall submit to the EPA
the name of the Facility Auditor selected and sufficient documentation demonstrating that each
of the criteria in Paragraph 69 are satisfied. If EPA disagrees that the Facility Auditor meets the
criteria in Paragraph 69, EPA shall notify Respondent within 10 business days of receipt of
notice. If EPA disagrees that the Facility Auditor meets the qualifications in
Paragraph 69, Respondent shall have an additional 30 business days to select a new Facility
Auditor. The criteria of this Paragraph shall be repeated until EPA does not notify Respondent
that it disagrees that choice of Facility Auditor satisfies the requirements of
Paragraph 69. -
Respondent and the Facility Auditor will understand and agree that:
a. The Facility Auditor will not be permitted to provide any other commercial, business, or voluntary services to Respondent for a period of at least two years following the Facility submittal of its final report; and b. Respondent will not provide future employment to the Facility Auditor or persons who managed, conducted, or otherwise participated in the audits for a period of at least two years following the Facility submittal of their final report. -
Notwithstanding Paragraphs 69 and 70, the Facility Auditor may assemble an auditing team to
be led by the Facility Auditor. The auditing team may include other employees of the Facility
firm or subcontractors meeting the criteria of Paragraphs 69 and 70 as well as
Respondent personnel. However, any Respondent personnel participants in the auditing team
shall not contribute to drafting of the Facility Report described in Paragraph 74. -
Respondent will ensure that the Facility Auditor leading the review:
a. Certifies that he/she satisfies the requirements specified in Paragraphs 69 and 70; b. Maintains contemporaneous records used in support of preparing the Facility Report; c. Prepares the Facility Report. Any of personnel that participated in the review team will not draft the Facility Report but will be permitted to provide factual information to the Facility Auditor and review drafts of the either report for factual accuracy; and d. Provides a copy of the final Facility Report to Respondent and EPA. -
Within 60 days after the completion of the Facility Audit, the Facility Auditor will provide a
Facility Report, including any Findings and Deviations, to Respondent and EPA. The Facility
Report will document:i. The date(s) of the review and describe how the review was conducted; 13Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006ii. Identify the names of all participants of the review team, including names, titles, employers and/or affiliations, and summaries of qualifications; iii. Describe all the types of information and records reviewed, and the equipment, processes, practices, structures, and other items reviewed, observed, or evaluated; iv. Document the Facility Auditor evaluation and findings as to each chemical substance subject to Sections 4, 5, 6, 8, 12, or 13 of TSCA and the regulations promulgated thereunder and describe the basis of those findings; and v. Provide a specific recommendation as to how each deviation from the TSCA requirements should be corrected to achieve conformity with the requirements. -
Within 30 days of completion of all conditions detailed in Paragraphs 64-74, Respondent will
submit to EPA itemized costs, documented by copies of invoices, purchase orders, receipts,
canceled checks, wire transfer records, and/or internal expense records that specifically identify
and substantiate any expenses incurred in carrying out the conditions detailed in Paragraphs 64-
74, including the retention of any independent third-parties as well as internal costs incurred by
using own personnel in fulfilling these conditions.VI. CIVIL PENALTY -
Pursuant to Section 325(c)(1) of EPCRA, 42 U.S.C. § 11045(c)(1), and consistent with Section
325(b)(1) of EPCRA, 42 U.S.C. § 11045(b)(1), and pursuant to Section 16 of TSCA, 15 U.S.C.
§ 2615, and taking into account the relevant statutory penalty criteria, the applicable penalty
policies, and Res EPA determined that a
Gravity Based Penalty of EIGHT HUNDRED, SEVENTY-ONE THOUSAND, EIGHT-
HUNDRED AND NINETY-NINE DOLLARS ($871,899) is appropriate. -
Pursuant to Section 16(a)(2)(C) of TSCA, 15 U.S.C. § 2615(a)(2)(C), and 40 C.F.R. § 22.31,
EPA agrees to remit TWO-HUNDRED THOUSAND DOLLARS ($200,000) of the civil
penalty for the TSCA violations alleged herein through the effective date of this CAFO,
V
reasonable satisfaction. -
Respondent agrees to pay a civil penalty in the amount of SIX HUNDRED, SEVENTY-ONE
THOUSAND, EIGHT-HUNDRED AND NINETY-NINE DOLLARS ($671,899) for the
alleged violations identified herein within thirty (30) days after the date the Final Order14Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006 -
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 EPA websites:
https://www.epa.gov/financial/makepayment and https://www.epa.gov/financial/additional-
instructions-making-payments-epa. -
When making a payment, Respondent shall:
a. s of this Agreement, TSCA-HQ-2024-5006 and EPCRA-HQ-2024-5006. b. Concurrently with any payment or within 24 hours of any payment, Respondent shall serve proof of such payment to the following person(s): Emilio Cortes Clerk of the Board U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460 Valarie Franklyn, Environmental Engineer U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460 [email protected] and U.S. Environmental Protection Agency Cincinnati Finance Center Via electronic mail to: [email protected] 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 -
Interest, Charges, and Penalties on Late Payments. Pursuant to 15 U.S.C. § 2615, 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 and15Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006
all accrued interest shall become immediately due and owing, and 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. To protect the interests of the United States the
rate of interest is set at the IRS standard underpayment rate, any lower rate would
fail to provide Respondent adequate incentive for timely payment.
b. Handling Charges
costs of processing and handling overdue debts. If Respondent fails to pay the
Assessed Penalty in accordance with this Agreement, EPA will assess a charge to
cover the costs of handling any unpaid amounts for the first thirty (30) day period
after the Filing Date. Additional handling charges will be assessed each subsequent
thirty (30) days, or any portion thereof, until the unpaid portion of the Assessed
Penalty, as well as any accrued interest, penalties, and other charges are paid in full.
c. Late Payment Penalty. A late payment penalty of six percent (6%) per annum, will
be assessed monthly on all debts, including any unpaid portion of the Assessed
Penalty, interest, and other charges, that remain delinquent more than ninety (90)
days.
-
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, interest, or other charges
and penalties per this Agreement, EPA may take additional actions. Such actions may include,
but are not limited to, the following.a. Refer the debt to a credit reporting agency or a collection agency, per 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, 40 C.F.R. Part 13, Subparts C and H. c. disqualify Respondent from doing business with EPA or engaging in programs EPA sponsors or funds, 40 C.F.R. § 13.17. d. Per 15 U.S.C. § 2615(a), the Attorney General may bring a civil action in the appropriate district court to recover the full remaining balance of the debt plus 16Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006interest. In such an action, the validity, amount, and appropriateness of the Assessed Penalty shall not be subject to review. -
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. -
Tax Treatment of Penalties. Penalties, interest, and other charges paid pursuant to this
Agreement shall not be deductible for purposes of federal taxes. -
Pursuant to 26 U.S.C. § 6050X and 26 C.F.R. § 1.6050X-1, EPA is required to send to the
Internal Revenue Service -
administrative settlements), that require a payor to pay an aggregate amount that EPA reasonably believ
nce with a
information provided to the IRS, to each payor (i.e., a copy of IRS Form 1098-F). Failure to comply with providing IRS Form W- below, may subject Respondent to a penalty, per 26 U.S.C. § 6723, 26 U.S.C. § 6724(d)(3), and 26 C.F.R. § 301.6723-1. In order to provide EPA with sufficient information to enable it to fulfill these obligations, EPA herein requires, and Respondent herein agrees, that:
a. Respondent shall complete an IRS Form W-
https://www.irs.gov/pub/irs-
pdf/fw9.pdf;
b. Respondent shall therein certify that its completed IRS Form W-9 includes
of a TIN;
c. Respondent shall email its completed Form W-
Center to Milton Wise at [email protected], within 30 days after the Final
Order ratifying this Agreement is filed, and EPA recommends encrypting IRS Form
W-9 email correspondence; and
d. In the event that Respondent has certified in its completed IRS Form W-9 that it has
applied for a TIN and that TIN has not been issued to Respondent within 30 days
after the Effective Date, then Respondent, using the same email address identified in
the preceding sub-paragraph, shall further:
i.
days after the 30 days after the Effective Date; and
17
Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006
ii.
VII. TERMS OF SETTLEMENT
-
Whenever this CAFO requires Respondent to give notice or submit reports, information, or
other documents to EPA, such information shall contain the date, the official's signature, and
the official's title and shall be accompanied by the following certification and such information
shall be submitted to Valarie Franklyn as described in Paragraph 80.b under this Agreement:To the best of my knowledge and belief after due inquiry, under penalty of law, I certify that the information contained in and accompanying this [fill in type of submission] is true, accurate, and complete. -
Recordkeeping. Respondent shall maintain all documents required under this CAFO, including
the EMS Manual, the Facility Report, and related documents for five years after they are
created and must produce them for inspection, copying or as otherwise required under Section
11 of TSCA, 15 U.S.C § 2610.Stipulated Penalties -
The following stipulated penalties accrue per day for missing the deadlines specified in
Paragraphs 65, 66, 67, 68, 70, 74, and 75:Penalty Per Violation Per Day Period of Noncompliance $1,000 1st through 14th Day $2,500 15th through 30th Day $5,000 31st Day and beyond -
After submission of the records required pursuant to Paragraph 75 expenses
incurred for implementation of Paragraphs 65-74 is less than the remitted penalties specified in
Paragraph 77 and a written demand has been made by EPA pursuant to Paragraph 90 below,
Respondent agrees to pay the difference between the total expenses incurred in the
implementation of Paragraphs 65-74 and the remitted penalty amount specified in Paragraph- To the extent Respondent submits internal expense records pursuant to Paragraph 75, those
internal expenses may only cover up to fifty percent (50%) of the remitted penalty amount
specified in Paragraph 77, though no such limit shall apply to expenses regarding the retention
of independent third-parties.
- To the extent Respondent submits internal expense records pursuant to Paragraph 75, those
-
Subsequent to the submission of the documentation of expenses incurred described in
Paragraph 75, EPA will make a written demand for civil penalties for any applicable stipulated18Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006
penalties associated with missed deadlines (Paragraph 88) and remitted penalties (Paragraph 89). Respondent will pay any applicable stipulated penalties, owing to the United States, not more than thirty (30) calendar days after receipt of the written demand from EPA. Except as otherwise specified in this Paragraph, payment of the penalty amounts specified in Paragraphs 88-89 will be made in accordance with the directions described in Paragraphs 79-85.
Other Terms
-
As a condition of this Agreement, Respondent may process, use, and distribute any existing
stocks of Chemicals A, B, C, D, and E in accordance with the applicable terms and conditions
of the approved TSCA LVEs (dates of approval being: March 7, 2024 for Chemical A;
February 1, 2024 for Chemical B; December 3, 2024 for Chemical C; January 1, 2024 for
Chemical D; and February 1, 2024 for Chemical E). -
If Respondent chooses to dispose of existing stocks of Chemicals A, B, C, D, or E, Respondent
will dispose of any unused portion of its existing stocks in accordance with applicable federal
and state requirements. Respondent should coordinate with the applicable state(s) where
disposal may occur to determine if additional requirements or a preferred approach (e.g.,
incineration) should be considered before disposing of the applicable Chemical Substance. -
This Consent Agreement may be amended or modified only by written agreement executed by
both the EPA and Respondent, and approval of the Environmental Appeals Board, except as
specified in Paragraph 94. -
Deadlines set forth in this Section, for submittals or performance may be extended by the
Branch Manager
Risk and Reporting Enforcement Branch, at his or her discretion, without further amendment of
this Order. The EPA will provide Respondent with written confirmation and documentation of
any such extensions of time.VIII. EFFECT OF SETTLEMENT AND RESERVATION OF RIGHTS -
In accordance with 40 C.F.R. § 22.18(c), completion of the terms of this CAFO shall only
alleged above.
-
By signing this consent 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 consent agreement. -
The terms, conditions, and compliance requirements of this Agreement may not be modified or
amended except upon the written agreement of both parties, and approval of the Environmental
Appeals Board, except as specified in Paragraph 94.19Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006 -
Compliance with this CAFO shall not be a defense to any subsequent action EPA may
commence pursuant to federal law or regulation for violations occurring after the date of this
Consent Agreement, nor any violations of TSCA or EPCRA not alleged in this Consent
Agreement that may have occurred prior to the date that this Consent Agreement is fully
executed by both Parties. -
Nothing in this Consent Agreement is intended to, nor shall be, construed to operate in any way
to resolve any criminal liability of Respondent.
100.
representations to the EPA in this matter.
-
All of the terms and conditions of this Consent Agreement together comprise one settlement
agreement, and each of the terms and conditions is in consideration for all of the other terms and conditions. This Consent Agreement shall be null and void if any term or condition of this Consent Agreement is held invalid or is not executed by all of the signatory parties in identical form or is not approved in such identical form by the EAB. -
Full payment of the penalty proposed in this Consent Agreement shall not in any case affect
the right of the Agency or the United States to pursue appropriate injunctive or other equitable relief or criminal sanctions for any violations of law. This Consent Agreement does not waive,
of TSCA and EPCRA, and the regulations promulgated thereunder.
- Nothing in this Consent Agreement shall relieve Respondent of the duty to comply with all
applicable provisions of TSCA and EPCRA and other federal, state, or local laws or statutes.
regulations, or 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. -
This Consent Agreement constitutes the entire agreement and understanding of the parties
and supersedes any prior agreements or understandings, whether written or oral, among the parties with respect to the subject matter hereof. -
This Consent Agreement shall take full effect upon the signing and filing of the Final Order
by the EAB.IX. OTHER MATTERS -
Respondent certifies that, to its knowledge, it is currently operating the Facility in
compliance with TSCA and EPCRA and their implementing regulations.20Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006 -
This Consent Agreement shall be binding upon the Parties, and their respective officers,
directors, employees, successors, and assigns. Respondent shall ensure that all contractors, employees, consultants, firms, or other persons or entities acting for Respondent with respect to matters included herein comply with the terms of this Consent Agreement. -
The undersigned representative of each Party certifies that he or she is duly authorized by
his or her respective Party to enter into this binding Consent Agreement. -
Complainant and Respondent, by entering into this Consent Agreement, each give their
respective consent to accept digital signatures hereupon. Respondent further consents to accept electronic service of the fully executed CAFO, by e-mail, at: [email protected]. Respondent understands that this e-mail address may be made public when the CAFO and Certificate of Service are filed and uploaded to a searchable database. -
This Consent Agreement shall not dispose of the proceeding without a final order from the
Environmental Appeals Board ratifying the terms of this Consent Agreement. This Consent
onmental
Appeals Board. Unless otherwise stated, all time periods stated herein shall be calculated in calendar days from such date.
112.
the scheduled civil penalty, paid any stipulated penalties, and completed and provided EPA with copies of all deliverables required to be submitted to EPA pursuant to this CAFO.
- Failure of Respondent to remit the civil penalties provided herein will result in this matter
being forwarded to the United States Department of Justice for collection of the amount due, plus stipulated penalties and interest at the statutory judgment rate provided in 28 U.S.C. § 1961.
114.
21
Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006
WE HEREBY AGREE TO THIS:
For Respondent:
Ryan J. Carra
Beveridge & Diamond
1900 N Street, NW, Suite 100
Washington, D.C. 20036
Counsel for Bedoukian Research Inc.
Date: _____
January 14, 2025
22
Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006
For Complainant:
Gregory Sullivan
Director
Waste and Chemical Enforcement Division
Office of Civil Enforcement
Office of Enforcement and Compliance Assurance
United States Environmental Protection Agency
Date: _____
N. Lindsay Simmons, Attorney
Waste and Chemical Enforcement Division
Office of Civil Enforcement
Office of Enforcement and Compliance Assurance
United States Environmental Protection Agency
Date: _______
23
Bedoukian Research Inc.
Docket Nos. TSCA-HQ-2024-5006
EPCRA-HQ-2024-5006
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24
Appendix A
CERTIFICATE OF SERVICE
I certify that copies of the foregoing “Consent Agreement” and “Final Order,” in the
matter of Bedoukian Research Inc., Docket Nos. TSCA-HQ-2024-5006 and EPCRA-HQ-2024- 5006, were sent to the following persons in the manner indicated:
By E-mail:
Counsel for Respondent:
Ryan J. Carra
Beveridge & Diamond
1900 N Street, NW, Suite 100
Washington, D.C. 20036
[email protected]
Counsel for Complainant:
N. Lindsay Simmons
Waste and Chemical Enforcement Division
Office of Civil Enforcement
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, D.C. 20460
[email protected]
Feb 06, 2025
Dated: ____ ______
Tommie Madison
Clerk of the Board
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