EPA v. MANUFACTURERS CHEMICALS, L.P.

Case summary

IN A LETTER TO EPA DATED JUNE 22, 1999, MANUFACTURERS CHEMICALS DISCLOSED THAT THE FACILITY MAY HAVE VIOLATED SECTION 8 OF TSCA. IN ITS INITIAL DISCLOSURE LETTER TO EPA DATED JUNE 22, 1999, THE FACILITY INDICATED THAT THEY WERE NOT IN COMPLIANCE WITH SECTION 8 OF TSCA IN THAT THEY HAD FAILED TO SUBMIT INVENTORY UPDATE REPORTING FORMS FOR 1998. THE FACILITY'S LETTER DATED JUNE 22, 1999, DID NOT CONTAIN ADEQUATE INFO TO DETERMINE WHETHER THE FACILITY WAS ELIGIBLE FOR A GRAVITY BASED PENALTY REDUCTION OR ELIMINATION. EPA REQUESTED ADDITIONAL INFORMATION FROM THE FACILITY IN A LETTER DATED DECEMBER 1, 1999. THE ACTUAL INSTRUCTIONS FOR COMPLETING IUR HAD BEEN MISPLACED AT THE FACILITY AND WERE FOUND ON JUNE 9, 1999. THE FACILITY BECAME AWARE THAT THE FORM HAD NOT BEEN FILED WITH THE PROPER AUTHORITIES ON JUNE 21, 1999, WHEN ONE OF THE COMPANY'S OFFICIAL CONTACTED EPA AND LEARN THAT THEY WERE NOT IN COMPLIANCE. ON JUNE 21, 1999, THE FACILITY CONTACTED EPA, REGION 4 AND WAS INFORMED AS TO THE SITUATION. THE COMPANY REPRESENTATIVE WAS PROVIDED WITH INFO CONCERNING THE AUDIT POLICY AND SUGGESTED THEY FILED A SELF- DISCLOSURE.

Defendants (1)

• MANUFACTURERS CHEMICALS, L.P.Named in settlement

Facilities (4)

• MANUFACTUERS SOAP & CHEMICAL CO., INC.

  4325 OLD TASSO ROAD, CLEVELAND, TN, 37311

  Registry ID: 110009492361

• MANUFACTUERS SOAP & CHEMICAL CO., INC.

  4325 OLD TASSO ROAD, CLEVELAND, TN, 37311

  Registry ID: 110009492361

• MANUFACTUERS SOAP & CHEMICAL CO., INC.

  4325 OLD TASSO ROAD, CLEVELAND, TN, 37311

  Registry ID: 110009492361

• MANUFACTUERS SOAP & CHEMICAL CO., INC.

  4325 OLD TASSO ROAD, CLEVELAND, TN, 37311

  Registry ID: 110009492361

Statutes cited

• TSCA 8 — Reporting & Retention of Information

Enforcement conclusions (1)

• MANUFACTURERS CHEMICALS, L.P.entered 2000-06-26

  Primary law: TSCA

Timeline (2 milestones)

• 2000-06-26Final Order Issued
• 2000-07-15Enforcement Action Data Entered