Document ZJyRN8EEw8VRVoLp27OZrg1oL

f t E A ~ United States ~., Environmental Protection , Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 09/27/2023 Toxic Substances Control Act (TSCA) New and Existing Chemicals (NEC) Program, also known as "Core TSCA" Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contacts: Technical Chemical Company Technical Chemical Company 3327 Pipeline Rd Cleburne, TX 76033 Same Same Johnson County (817) 645-6088 Gary Williams (817) 645-6088 Ruben Morales (817) 645-6088 Vice President of Operations Technical Services Director FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000506667 N/A N/A 325998 - All other miscellaneous chemical product & preparation manufacturing N/A Personnel participating in inspection: David Riley US EPA Region 6 (ECDST) Ruben Morales Technical Chemical Company - - - - Inspector Technical Services Director EPA Lead Inspector Signature/Date Supervisor Signature/Date ~Dd~ John" David Riley - I I S-r//' /} ~ y- H. Troy Stuckey lrJ1-2L; Date 11/27/23 Date 6ENFORM-020-R8.2 (02/12/2020) 1 Section I - INTRODUCTION Technical Chemical Company Inspection Date 09/27/2023 PURPOSE OF THE INSPECTION The purpose of this inspection is to evaluate Technical Chemical Company (TCC) of Cleburne, Texas, for compliance with Sections 4, 5, 8, 12, and 13 of the Toxic Substances Control Act (TSCA), also referred to as the New and Existing Chemicals (NEC) program, or "Core TSCA". These Sections are as follows: 4 - Testing of Chemical Substances and Mixtures 5 - Manufacturing and Processing Notices 8 - Reporting and Retention of Information 12 - Exports 13 - Entry into Customs Territory of the United States The inspection was conducted pursuant to Section 11 of TSCA. The Core TSCA program is not statedelegated; therefore, inspections are conducted by the EPA. This is a "neutral scheme" inspection covering the calendar years 2016 to the present. EPA initially reviewed information from US Customs & Border Protection, which showed TCC as an importer of chemical substances for the years 2016 through 2023. EPA information contained several locations for TCC, either in Cleburne, or in Dallas, TX. It was determined that the 3327 Pipeline Road facility in Cleburne was the main location, and it was selected for an inspection based on further reviews of EPA information sources, as well as no record of prior TSCA inspections. On September 6, 2023, I, David Riley of US EPA Region 6, initially contacted the company by phone and left a message for Gary Williams, Vice President of Operations. I spoke with Mr. Williams on September 11th, and the inspection was scheduled for Wednesday, Sept 27th, at 10:00am. As Mr. Williams was already scheduled to be out of the office that week, he indicated that he would relay any related information to his team. On September 12th, I sent Mr. Williams an inspection notification email containing a list of information that the company should prepare for review and collection by the inspector [Appendix 1]. The following day, I received a call from Ruben Morales, Technical Services Director, with some questions on the information in the email. On September 18th, I received an email from Mr. Morales with some general background information on TCC. INSPECTION ENTRY & OPENING CONFERENCE I arrived at the facility at 9:55am on September 27, 2023. I entered the reception area and was met by Mr. Morales, who escorted me to a conference room. I presented my inspector credentials and a business card to Mr. Morales and informed him that the inspection would involve a review and discussion of the information requested in Appendix 1. At that time, Mr. Morales signed the Notice of Inspection [Appendix 2]. 2 COMPANY HISTORY & FACILITY DESCRIPTION Technical Chemical Company Inspection Date 09/27/2023 Technical Chemical Company was originally located in Dallas, TX at 10737 Spangler Road (Facility Registry Service [FRS] # 110000457407). In 1989, this site was expanded to 10377 Spangler Road (FRS # 110010656049), but this address number was not used. In January of 2001, the company relocated to the current location at 3327 Pipeline Rd. in Cleburne, TX (FRS # 110000506667). In 2003, another building at 400 Commerce Boulevard in Cleburne (FRS # 110034794275) was opened for shipping and warehousing. Initial products were primarily brake fluid, power steering fluid, and lubricating oils. Currently, the facility blends and packages various refrigerants, aerosols, and automotive fluids. Technical Chemical Company has 258 full-time employees and 80 to 100 temporary employees. Sales range from $ 150 - 250 million. Section II - OBSERVATIONS DISCUSSION The inspection began with a review of company specifics and process flow. The company blends various chemical substances on-site, with no reactions to form new chemical substances. Packaging is also performed on-site. Approximately 65% of manufacturing and packaging is for privately contracted brands, with the remaining 35% for brands owned by Technical Chemical: Johnsen's Blue Magic, QuikSteel, Turbo 108, Pure Citrus, Seal-UP, Hi-Tach, Emergency Quick Flat Fix, and Freeze. Raw materials for all products are purchased domestically or imported, with Technical Chemical Company as the importer of record. Imported chemical substances function as starting fluids, propellants, and refrigerants. No finished products are imported. Several spreadsheets were reviewed with information on imported raw materials, import details, exported finished goods, export details, and specifics on company manufacturing operations and processes. TCC planned to claim these as confidential business information (CBI), so options for submitting this information to the EPA were discussed. FACILITY TOUR At approximately 11:15am, Mr. Morales led me on a tour of the raw material storage area, process area, packaging lines, and finished product storage areas. 3 FACILITY DOCUMENTATION Technical Chemical Company Inspection Date 09/27/2023 The only document collected at the time was a visitor requirements sheet specifying procedures to be followed while on-site. This document contains a basic map of the facility layout. TCC was in the process of compiling some additional information for submittal as CBI. It was agreed that TCC would keep me informed of their progress and submit the information later. Section III - AREAS OF CONCERN I observed no areas of concern at the time. Facility representatives were very cooperative prior to and during the inspection. CLOSING CONFERENCE At 11:40am, I conducted a closing conference with Mr. Morales, indicating that I would follow up with any questions, and that an inspection report would be finalized in approximately two months. We discussed some modifications to the deliverables specified in the inspection notification email. The Notice of Proprietary/Confidential Business Information {Appendix 3] was signed by Scott Dudley, President of TCC, and Mr. Morales signed the Receipt for Samples and Documents [Appendix 4]. The TSCA Notice of Inspection, TSCA CBI Notice, and Receipt for Samples and Documents were then copied, and the originals were returned to me. I exited the facility at 12:00pm. Section IV - FOLLOW UP On 10/5/23, Mr. Morales submitted Safety Data Sheets for various finished products via email. On 10/23/23, TCC submitted items claimed as CBI via the EPA's Central Data Exchange (CDX) system. Some information gathered from emails with the company has been incorporated into the body of this report. Section V - LIST OF APPENDICES Appendix 1 - Inspection Notification Email Appendix 2 - Notice of Inspection Appendix 3 - TSCA CBI Notice Appendix 4 - Receipt for Samples and Documents 4 Technical Chemical Company Inspection Date: 09/27/2023 Appendix 1 Inspection Notification Email Riley, David From: Sent: To: Subject: Riley, David Tuesday, September 12, 2023 3:54 PM gwilliams@technicalchemical.com TSCA inspection of Technical Chemical Company; Cleburne, TX Hello Mr. Williams, This email is a follow up to our communication of September 11, 2023. Please reply to this email acknowledging its receipt. Pursuant to Section 11 of the Toxic Substances Control Act (TSCA), the EPA will conduct an inspection of the Technical Chemical Company facility in Cleburne, TX, on Wednesday, September 27, 2023, at 10:00am. The purpose of the inspection is to evaluate compliance with TSCA Sections 4, 5, 8, 12, and 13. In order to expedite the process, the EPA is requesting information from Technical Chemical Company. It is preferred that this information be provided in advance of the actual site visit; however, if more time is needed, please let me know. Specifically, the EPA is seeking the following information: 1. General Background information Brief company history of ownership and business. Corporate structure (including foreign and domestic parent companies). Listing of all U.S. facilities owned by the company, including subsidiaries, and their locations. Number of employees at the facility and corporate level. Gross annual sales at the facility and corporate level for the last four complete years or accounting cycles (note the fiscal cycle) rounded to at least three significant figures. Identifying information for the facility and U.S. parent company, including data universal numbering system (DUNS) number. Importer of Record ID for all sites that import into the U.S. that are owned by the U.S. parent company. Scope of business, main North American Industry Classification System (NAICS) codes under which the site operates, and main industries that the company and site supply. Facility and/or corporate policies developed to ensure compliance with TSCA Sections 4, 5, 8, 12, and 13. 2. Imported and/or Manufactured Chemical Substances. Prepare a separate spreadsheet of chemical substances that were manufactured (including those imported) by the facility for the current calendar year and the past 7 calendar years (2016 - present). If a chemical substance is a hydrate under the definition of mixture pursuant to 40 C.F.R. 710.3, please include Chemical Abstracts Service Registry Number (CASRN) of both the hydrate and the anhydrous forms of the chemical substance. The spreadsheet should include the following information: Chemical Abstracts Service (CAS) number or the EPA Accession Number; Accepted Chemical Name Product or Trade name; Dates of manufacture, including import; Quantity manufactured per batch, including quantity imported per shipment and shipment number; 1  Whether the chemical substance is Manufactured or Imported, or both; HTS Code used if imported. If applicable, indicate if the chemical substance is being manufactured/imported under an exemption [e.g. R&D, Low Volume Exemption (LVE), Test Marketing Exemption (TME), Polymer Exemption (PE), or Low Release/Low Exposure (LoREX)]. Also, please provide Safety Data Sheets (SDS) for all products listed in the spreadsheets. 3. Domestically Acquired Raw Materials. Prepare a separate spreadsheet listing the raw materials (including mixtures) acquired from domestic suppliers that were used or processed by the facility for the current calendar year and the past 5 calendar years (2018 - present). The spreadsheet should include the following information: CAS number or EPA Accession Number; and The suppliers name and address 4. Process Flow Diagrams. Provide manufacturing and processing flow diagrams for substances either manufactured or processed at the facility. List each raw material input and the resulting products (by Chemical Abstracts Service Registry Number (CASRN) or EPA Accession Number) for each step between the particular raw material and the commercial product, including intermediates, byproducts, and catalysts, that are part of the commercial production but are not intended for sale or distribution. Indicate all steps including on-site use, transfer, recycling, and waste disposal. 5. Exported Chemical Substances. Prepare a separate spreadsheet of chemical substances and the components of each mixture of the products that were exported from the United States by the facility for the current calendar year and the past 5 calendar years (2018 - present). List each unique CASRN only once and only if the chemical substance makes up one percent or greater of the volume of the product. The spreadsheet should include the following information: CAS number or the EPA accession number for each chemical substance; Accepted chemical name(s) of each component; Export date; Final destination (foreign country); On the last page of the company's response, the following certification should be signed by an officer or other responsible corporate official (e.g., president, secretary, treasurer, or vice president) in charge of a principal business function, or another executive with authority to perform similar policy or decision-making functions for the Facility when it was in operation: "I certify that I am fully authorized by Technical Chemical Company to provide the above information on its behalf to the U.S. Environmental Protection Agency (EPA) in response to EPA's email dated September 12, 2023. I certify under penalty of law that this response and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for knowingly submitting false information, including the possibility of fines and imprisonment for knowing violations." Signature ____________________ Name ____________________ 2 Title ____________________ If none of the requested information is subject to claims of confidential business information (CBI) by Technical Chemical Company, please email the information to the inspector. If Technical Chemical Company is making claims of CBI on any of the requested information, please inform the inspector via email, and further instructions will be provided. Do Not Email CBI. Notice Regarding CBI Collected in Connection with a Compliance Monitoring Activity. Under Section 14(a) of TSCA, 15 U.S.C. 2613(a), submitters may claim information submitted to the EPA under TSCA as Confidential Business Information (CBI). TSCA CBI claims must be asserted and substantiated concurrently with the submission of the information, except for those types of information exempt under TSCA Section 14(c)(2). There are several procedural requirements that must be followed when asserting CBI claims in TSCA submissions. The authorized official submitting TSCA CBI claims must make several assertions as well as certify that information submitted to substantiate a TSCA CBI claim is true and correct, as required by Sections 14(c)(1)(B) and 14(c)(5) of TSCA, 15 U.S.C. 2613(c)(1)(B) and (c)(5), and 40 C.F.R. 2.208. The certification statement provided below will satisfy these requirements. General guidance for what to include in TSCA CBI substantiations, including several sample substantiation templates, are available here: https://www.epa.gov/tsca-cbi/what-include-cbi-substantiations#substantiationtemplates For information claimed CBI, provide the certification statement below. For information that is not exempt from the substantiation requirements, please provide a written substantiation statement. EPA strongly recommends including a sanitized version of any CBI documents. EPA has observed that a company-sanitized version most accurately indicates the company's CBI claims and the intended scope of each claim, and avoids misunderstandings that might arise in the event EPA must prepare a sanitized version in response, for example, to a FOIA request. All information claimed as CBI must be clearly identified as such. CERTIFICATION STATEMENT FOR TSCA CBI CLAIMS I hereby certify to the best of my knowledge and belief that all information claimed as TSCA CBI provided with this statement is complete and accurate. I also understand that I must submit a substantiation statement for any information which I claim to be TSCA CBI which is not exempt from the substantiation requirements. I further certify that, pursuant to 15 U.S.C. section 2613(c) and 40 C.F.R. 2.208, for all claims for confidentiality made with this submission, all information submitted to substantiate such claims is true and correct, and that it is true and correct that: i. My company has taken reasonable measures to protect the confidentiality of the information; ii. I have determined that the information is not required to be disclosed or otherwise made available to the public under any other Federal law; iii. I have a reasonable basis to conclude that disclosure of the information is likely to cause substantial harm to the competitive position of my company; and iv. I have a reasonable basis to believe that the information is not readily discoverable through reverse engineering. This request for submission of information is not subject to the approval requirements of the Paperwork Reduction Act of 1980, 44 U.S.C. Section, 3501 et seq. If you have any questions regarding this request, please contact me. 3 Thank you, David Riley Inspector/Enforcement Officer Core TSCA, EPCRA 313 US EPA Region 6 (ECDST) 1201 Elm Street, Suite 500 Dallas, Texas 75270-2102 Phone: (214) 665-7298 e-mail: riley.david@epa.gov 4 Technical Chemical Company Inspection Date: 09/27/2023 Appendix 2 Notice of Inspection .&EPA Uniled Statos Envi,oom~nial P,otoclio<> Agency United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 Notice of Inspection Office of Enforcement and Compliance Assurance 1. Investigation Identification 3. Facility Name Date 'l ,11-12~ Inspection Number .1 Daily Seq. Number I 1,,f 1 I I~ ,.hMc,I Chc,h, c.a) Co= r0 0 vy 2. Inspector's Address 4. Facility Address }'20' f=!,,n v ' ' r ,;... :r+c 500 :P,llsr '/ ' -,: 'C:/,52'.fO 357..T' f.rc 1,-~ IE' J - CI, l,;,,,-1-e , Tx =J,60]'2, For Internal EPA Use. Copies may be provided to the recipient as acknowledgment of this notice. Reason for Inspection Under the authority of Section 11 of the Toxic Substances Control Act For the purpose of inspecting (including taking samples, photographs, statements and other inspection activities) an establishment, facility or other premises in which chemical substances or mixtures, articles containing same are manufactured, processed, stored or held before or after their distribution in commerce (including records, files, papers, 'Ds{ processes, control and facilities) and any conveyances being used to transport chemical substance, mixtures or articles containing same in connection with their distribution in commerce (including records, files, papers, processes, controls and facilities) bearing on whether the requirements of the Act are applicable to the chemical substances, mixtures or articles, within, or associated with, such premise or conveyance have been complied with. D In addition, this inspection extends to (check appropriate blocks): D A. Financial Data D D. Personnel Data D B. Sales Data D E. Research Data D C. Pricing Data The nature and extent of inspection of such data specified Jn A through Eabove is as follows: Signature Inspector's /IJ)f0 Q,o Recipient's Signature Name 0o k~ J)A,: d R:i~ "'Title fr,.;foM'"'1o\ .Sc,er.+,,t Date I IZ't/i?- Name~ (Y\~ I I Title I\. Date : -c6,...~,,(\\ S:c-vS<:c; \i; n'l--Z..7-'Z b EPA form 7740-3 (Rev. 2/16) 1-lnspector Copy 2-Facility Copy Technical Chemical Company Inspection Date: 09/27/2023 Appendix 3 TSCA CBI Notice oEPA Un11~d Slates En,i,or1rneo1al Prnrnct,on Agency UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Notice for Toxic Substances Control Act (TSCA) Inspections NOTICE REGARDING PROPRIETARY/CONFIDENTIAL BUSINESS INFORMATION (CBI) SUBMITTED TO OR COLLECTED BY EPA IN CONNECTION WITH INSPECTIONS AND OTHER COMPLIANCE MONITORING For information submitted to or obtained by the U.S. Environmental Protection Agency (EPA or Agency) during or after an inspection (or other compliance monitoring), regulated entities (e.g., businesses, facilities, etc.) may assert a confidentiality claim on information that it believes is a trade secret or as privileged or confidential commercial or .financial information, which is protected under Exemption 4 of the Freedom of Information Act (FOIA) at 5 U.S.C. 552(b)(4). This type of information is commonly referred to as CBI or proprietary business information (PBI). For consistency purposes, the term CBI will be used within this document. Under section 14 ofTSCA, regulated entities (e.g., businesses, facilities, etc.) have a right to claim certain information submitted to the EPA in connection with an inspection (or other compliance monitoring) as CBI. 15 U.S.C. 2613. This document provides instructions for asserting a CBI claim, underTSCA, on the business information that you provided to EPA during or after its inspection based on the time limitations defined below. EPA is giving you this Notice so that you have the opportunity to request confidential treatment of your business information in order to ensure that EPA properly handles your business' CBI claims. If your business believes that any information that EPA will be viewing or collecting during the inspection of your business may be CBI, EPA requests that a representative of your business who has the authority to claim that information as CBI, read, fill out and sign this Notice. You must read and follow all instructions for properly giving EPA notice of your CBI claim. If you have questions about this Notice, you or a representative of your business with the authority to assert the CBI claim may request clarification from the EPA inspector or call the contact name that the inspector will give you with this Notice. EPA has also created a Questions and Answers document for this Notice that you may find helpful and is available at: https://www.epagov/compliance/cbi-noticeinformation-col!ected-durint?:-epa-inspections-or-other-compliance-monitoring If a CBI claim does not accompany the information submitted to EPA, 01 is not submitted within 10 calendar days following an inspection, as desc1ibed in Paragraph (A)(l)(b), below, then the Agency may make the information available to the public without fm1her notice. For example, the Agency may make inspection reports available to the public, including through this website at https://echo.epa.gov. Also, EPA may be required by law to release the information to the public. 1 For example, the FOIA requires the disclosure of Agency records that have been requested by a FOIA request unless that information falls within a FOIA exemption. However, EPA does not release information claimed as CBI to the public in response to a FOIA request. In addition, EPA is required under section 14 ofTSCA to routinely review (and approve or deny) all but some exceptional CBI claims for chemical identity, and a representative subset, comprising at least 25 percent, of other types of TS CA CBI claims. 15 U.S.C. 2613(g). Information that you claim as CBI in accordance with TSCA section 14 will be held as such until the CBI claim is withdrmvn, expires, or is denied by EPA, in accordance with TSCA section 14 and 40 C.F.R. Part 2, Subpart B. 1 Information covered by a CBI claim will be disclosed by EPA only to the extent of, and by means ot: the procedures set forth in 40 C.F.R. Part 2, SubpartB I (A) Procedures to claim c01tfide11tial treatment for i11formatio11 provided to EPA. (1) You may assert a CBI claim covering part or all of the information submitted to or obtained by EPA: (a) at the time of the inspection; (b) within IO-calendar days2 following the inspection for information submitted to or obtained by EPA during the inspection; or (c) at the time of submittal, if you submit information requested before or after the inspection. (2) If you fail to assert a CBI claim before an inspection, during an inspection, or within the 10-calendar day period following the inspection, the information may be made available to the public by EPA without further notice to the business. (3) EPA's CBI regulations are at 40 C.F.R. Part 2, Subpart B (sections 2.201-2.311). See h11ps://www.ecfr.g0Y. (B) Method and time ofasserting husi11ess confidentiality claim. (1) Under TSCA section 14(c), you are required to substantiate each CBI claim (with some exceptions, described in TSCA section 14(c)(2)), provide certain certification statements, and, for CBI claims concerning chemical identity, provide a structurally descriptive generic name. All of this information must be provided at the time the information claimed as CBI is submitted to EPA. More information on how to assert a claim under TSCA may be found at https://www.epa.go\'/tsca-cbi. (2) A business that is submitting information to EPA may assert a business confidentiality claim by highlighting, bracketing, boxing, or circling the infonnation claimed as CBI, and marking the page or document with language such as trade secret, proprietary, company confidential, PB!, or CBI. You may also provide a "sanitized" or non-confidential version of the document, with all CBI removed to facilitate identification and handling of CBI by EPA.3 If your business requests confidential treatment only until a certain dale or until a certain event happens, then please indicate this at the time your business makes its CBI claim. The Notice includes a box (page 4) that you or the inspector may use to list and generally describe the CBI claims; add an attachment if more space is needed. (3) For documents that EPA inspectors collect or copy during the inspection, a representative of the facility should provide a general description of information that is claimed as CBI in those documents when provided to the inspector. Substantiation, certification, and generic name(s) (when applicable) may be provided to EPA following the inspection, but must be received by EPA within 10 calendar days after the inspection. Similarly, assertions that photos taken by EPA include or may include CBI should be made at the time of the inspection by a representative of the facility. Such assertions should generally describe what is considered CBI by the business, for example, specific equipment or processes. Substantiation of these CBI claims must be provided within 10 calendar days following the inspection. CBI claims to documents and photos taken or collected during the inspection that are not substantiated ,vithin this IO-calendar day timeframe or are otherwise not complete according to TSCA section 14(c), will be considered by EPA to have been withdrawn. Substantiation should be directed to the address for the EPA inspector identified on the sheet attached to this notice. 2 The IO-calendar day period begins on the day after an inspection concludes. For example, if the inspection of your business commenced on Monday and concluded on Tuesday, the 10-calendar day period begins on Wednesday. If the 10-calcndar day period ends on a weekend day or a holiday your claim must be postmarked, or EPA contacted by telephone by the next business day. In certain instances EPA may find it necessary to disclose the infonnation obtained during the inspection and not claimed as CBI before the I0-calcndar day period expires, and as such, EPA may provide the affected business less than IO-calendar days following an inspection to assert a CBI claim. 3 You should indicate, but not black out, white out or remove, all CBI in the documt.'Ilts you submit to EPA so that the CBI remains visible for EPA to read. Only marking the document or page as confidential or the like is not sufficient to assert a proper CBI claim. In addition to submitting the document with legible CBI, you may also submit a copy of the document with the CBI blacked out or removed, but you may not submit only a document with the CBI blacked out or removed (a "sanitized copy."). EPA treats the sanitized copy as a publicly available document. 2 (C) Substautiatiou ofbusiness c01ifide11tiality claim, Unless the infonnation is exempt from the substantiation requirement under TSCA section 14(c)(2), substantiation must be provided with TSCA CBI claims at the time they are asserted and submitted to the agency (but note the IO-calendar day period discussed in paragraph (B) for materials collected during an inspection). EPA has developed several submission type-specific and general templates that may be used to provide substantiation (use of the templates is recommended, but not required) and has provided additional guidance on what to include in a substantiation on the EPA TSCA CBI webpage: https://www.epa.gov/tsca-cbi The questions included in 40 C.F.R. 2.204(e)(4) and the substantive criteria at 40 C.F.R 2.208 may also serve as a useful guide to what to include in a TSCA CBI substantiation. (D) Certai11 information not eutitled to co1tfide11tial treatmeut. Infonnation that is publicly available at the time of inspection, or that is required to be disclosed to the public by law, is not entitled to confidential treatment and should not be claimed as CBI. While this is not a comprehensive list, the follO\ving types of infonnation generally are not protected as CBL infonnation that is publicly available; information that was submitted to a federal, tribal, state or local government that was not claimed as CBI; information prohibited by law as CBI, such as effluent data, emissions data, or health and safety data in health and safety studies (see, e.g., TSCA section 14(b)). If a business makes a claim on any such infonnation, EPA may make a determination under 40 C.F.R. 2.204(d)(2) that the information is clearly not entitled to confidential treatment. See Attachment A, Questions and Answers about this Notice, for some examples of what is and is not entitled to confidential treatment. 3 $EPA UMeds,,,w, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY PROPRIETARY/CONFIDENTIAL BUSINESS INFORMATION NOTICE En,i,onn,.Hl!>I P,o,wio<> Asency FOR TSCA INSPECTIONS - Facility: I <:C.hoJc ,!) CLr~,col Co,,..,"""J Facility Address: ?r, t <. ?.7.,"l- ;>e i I.,{' RJ, ~ / e bv r,,._ f , / 'X Facility Representative with authority to make a CBI' Inspection NumbCr: J... 1/,037, claim (print name & title): r ()"it 1)1.!' cl \e''t' ?f~s:de~\ i Te,,l~,, 0\ Ch,~,e, \ Co~i"" 1s Date: 1I,.-:i- I1.:,, <, Signature( / I(,.,/ //'P P~rf:~s-<.,c%X'flt6_ ~-A -_nJ- ,,R;...1.....- 1 .. !/ ./ - l:.! J EPA Inspector (print): ~J ~ D , R, 1 C /\ f}I\JJ ,,. I \.l~ ~ Dale; '1/-r+h., Address: [mailing or courier address appropriate for inspector and/or inspector's Document Control Officer] /ZO/ <,I~ s-+, S+t:, 5~ Phone'z.l'f . bbS. :J.?."\-X Email: Dc-1/0.5 1--ry "/-5Q.-=f-O r; lee\' J.v: J a) Cf""- :'I" ~ I have received this Notice and DO NOT make any CBI claim on the documents and information 1 have orovidcd to EPA at this time. I 11ndersland that. wit/tin JO-calendar days ofthe date oftltis inspection, ifI determine that any ofthe documents and information I provided to l!,7)A are CBI, I may send a written notice to the EPA inspector (address and email listed above) identifying the specific information I wish to claim as CBI. I fitrther understand Lhat ifno CBI claim was made at the time ofthe inspection or within the 10-ca/endar day period following this inspection, the information may be made available lo the public by EPA withoutfiirther notice to the business.' ,Yee 40 C.F.R. 2.203. / ~ / I have received this Notice and DO make a CBI claim regarding the documents and infonnation listed below that I have nrovidcd to EPA. 11 ltereby certify to tlte best ofnry knowledge and beliefthat all informatio11 entered 011 this form is complete and accurate. /further certify that, pursuant to 15 U.S.C. 2613(c).for all claims/or confidentiality made with this submission, all information submilted to substantiate such claims is trtte and correct, and that it is true and correct that ;. My business has taken reasonable measures to protect the confidentiality oftlte btformation; ii. I have determined that the information is ,wt required to be disclosed or otherwise made available to the public under any otlter Federal law; iii. I have a reasonable basis to conclude tltat disclosure oftlze informatio11 is likely to cause substantial ltarm to tlte competitive positioll ofmy business; and iv. I have a reasonable basis to believe that the information is not readily discoverable tltrouglt reverse engineering. Any knowing andwillfi1l materiallyfa/se,fictftious, orji-audulent statement or representation is subject to criminal oenaltv oursuant to 18 U.S.C. ~ 1001. 4 Part B of this Notice explained how to identify information claimed as CBI. You or the inspector may use this box to list and generally describe any CBI claims. For clarity, please be as specific as possible. Example: Internal layout of facility. \;1.\\-, ~c~J--\ 0.,_ '><o I~ ),._6 0 ~ ..\,\..e_ "-1'<-e'l '\- ' ~J;_ ' \ r"1. oo,4e.!. ._"" w \l"'--C\... \-._<" \ a..'6- ., s\_;(-e-1. s ' S:-ovr-ce,.---S. ;;;:i.,,.. 0 -'(' g..,,._,,,,..,,,) ..,..., ~ , Cl,o~oCIS a \ec,,,J,c<-J \c.c,\l<-.1 ' ~\,,,_, t,60,.CC ' '- \c:C'.i,,,..,,. {'f\ t1 ~. '2.'7 7.6Z:, (Revised: Janua,-y 2021) Attach add1l10nal sheets, 1fnccdcd. 5 O,-iginal lo EPA I Copy lo Facility Technical Chemical Company Inspection Date: 09/27/2023 Appendix 4 Receipt for Samples and Documents &EPA Unit~d s,~to, Environmental Proleotion A9oncy United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 Receipt for Samples and Documents Office of Enforcement and Compliance Assurance 1. Investigation Identification 2. Company Name Date Inspection No. I9[-z::i-J," I i 3. Inspector Address /201 ('("" J"1 ) s+e "500 o,,."11"" D 1".52'.\-0 Daily Seq. No. 11.t 1. I TeclJ\1'>- I'\ Ck-i~ '\ 4. Company Address Co,--J"'~ ' "i- ' 332,- P,pcl",_, /20- d Clibv,~~ -,,, "1"605:, For internal EPA use. Coples of this form may be provided to recipient as acknowledgment of the documents and samples of chemical substances and/or mixtures described below collected in connection with the administration and enforcement of the Toxic Substances Control Act. Receipt ofDocument(s) and/or Sample(s) Described is Hereby Acknowledged: No" 1 ~ Description I I ,CG V:.r,+~r Je.e)v;rC~e/rF pf".r fr,~f - ~ i ~ , ~ ' \.--3/~ ~ ~ ~ ~ Optional: Duplicate or Split Samples: Requested and Provided D Not Requested D Inspector's Signature {)~, ~ D V " Name J;L D.,, J (<.,(." Title E11v:1',~..-I. I S,.,,i,,f Date I1fr~/1 J EPA Form 77401 (Rev.2/16) Claima~0.\~ Signature l\i:""". , Name I~\St, iJ (l(\d ?.A-Cc> I ITitle "' c.c~ ~<>v\~s I Date I 0 9 / 2-'l/z.~ \) \1e..c...--\~pectorCopy 2-Facility Copy