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Message From: Sent: To: Subject: Jennifer Gibson [JGibson@NACD.com] 5/26/2017 2:33:18 PM Beck, Nancy [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=168ecb5184ac44de95a913297f353745-Beck, Nancy] RE: NACD Member Egregious Enforcement Case - Time Sensitive Thanks very ranch, Nancy. We really appreciate It, Best regards, Jennifer Jennifer C,, Gibson Vice President, Regulatory Affairs Rational Association of Chemical Distributors (MACD) ChMellemmk From: Beck, Nancy [mailto:Beck.Nancy@epa.gov] Sent: Friday, May 26, 2017 9:56 AM To: Jennifer Gibson <JGibson@NACD.com>; Gunasekara, Mandy <Gunasekara.Mandy@epa.gov> Cc: Eric Byer <ebyer@NACD.com> Subject: RE: NACD Member Egregious Enforcement Case - Time Sensitive Hi Jennifer, I am working with staff to try to track it down. Regards, Nancy Nancy B. Beck, Ph.D., DABT Deputy Assistant Administrator, OCSPP P: 202-564-1273 beck.nancy@epa.Rov Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00044836-00001 From: Jennifer Gibson [mailto:JGibson@NACD.coml Sent: Thursday, May 25, 2017 2:50 PM To: Beck, Nancy <Beck.Nancy@epa.gov>; Gunasekara, Mandy <Gunasekara.Mandy@epa.gov> Cc: Eric Byer <ebyer@NACD.com> Subject: RE: NACD Member Egregious Enforcement Case - Time Sensitive Hello Again, Nancy. 1am checking in with you to see if you have learned anything on this case. Brenntag received their settlement offer today from Region 4. EPA is sticking with the $19,410 penalty with the option of a 75% SEP, 25% straight penalty. Brenntag has until June 9 to respond to EPA. Thanks so much for your assistance. Best regards, Jennifer Jennifer C, Gibson Vice President, Regulatory Affairs National Association of Chemical Distributors (NACD) CherniesI D IstA o t 1560 Wilson Bird., Suite 1100 Arlington, VA 22209 (703) 527-62231 ix.6 I Main Line i Ex. 6 } Direct i g ibso n@ na cd .co m IM&ifll From: Beck, Nancy [mailto:Beck.Nancy@epa.govl Sent: Monday, May 22, 2017 6:54 PM To: Jennifer Gibson <JGibson@NACD.com>; Gunasekara, Mandy <Gunasekara.Mandv@epa.gov> Cc: Eric Byer <ebver@NACD.com> Subject: RE: NACD Member Egregious Enforcement Case - Time Sensitive Jennifer, Thanks for this information. TRI is in OCSPP now. I will see what I can learn about this one from our staff. Regards, Nancy Nancy B. Beck, Ph.D., DABT Deputy Assistant Administrator, OCSPP P: 202-564-1273 Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00044836-00002 M:jL____E_X__._6____ ! beck.nancy@epa.gov From: Jennifer Gibson [mailto:JGibson@NACD.coml Sent: Monday, May 22, 2017 3:05 PM To: Gunasekara, Mandy <Gunasekara.Mandy@epa.gov>; Beck, Nancy <Beck.Nancy@epa.gov> Cc: Eric Byer <ebyer@NACD.com> Subject: NACD Member Egregious Enforcement Case - Time Sensitive Dear Mandy and Nancy, It was nice to see you last week at NACD's meeting with Administrator Pruitt. As a follow up, Eric Byer and I are working to collect troubling enforcement examples from our members with a goal of getting these to you this week, or early next at the latest. In the meantime, one of our members, Brenntag, reached out to me on Friday with an immediate example from Region 4. EPA is proposing a five-figure penalty for failure to hit the certify button for one chemical when submitting a Toxic Release Inventory report. A description of the case is attached. This is a perfect example of extreme monetary penalties issued for minor administrative errors that result in no harm to the environment and of the "Find & Fine" enforcement approach we discussed. In this case, even the agency's rationale for the large penalty is flawed. Can you assist with this? We are curious to know if Region 4 even vetted this penalty through EPA headquarters as this seems completely contrary to the approach Administrator Pruitt indicated he would like the agency to take. Please let me know if you need any additional information. Thank you so much for your consideration. Best regards, Jennifer Jennifer C. Gibson Vice President, Regulatory Affairs Rational Association of Chemical Distributors (MACD) CheRstol fiRti 1560 Wilson Biv'd., Suite 1100 Arlington, VA 22209___ _ (703) 527-6223 L.S-..J Main Line (703) 527-7747 - Fax 6! IC e ll i Direct ifliBson^McOorn"' U Q Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00044836-00003