Document g2zXMRBv11MapMRpK4e0MMMea

ft E A ~ UnitedStates ......, Environmental Protection , Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 03/30/2023 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 Contact: RTP Company RTP Company 1301 Joel East Road Fort Worth, TX, 76140 Same Same Tarrant County (817)293-5880 Todd Reynolds treynolds@rtpcom pa ny.com I I VP of Facilities & EHS FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000459833 N/A N/A 325991- Custom compounding of purchased resins N/A Personnel participating in inspection: David Riley US EPA Region 6 (ECDST) Todd Reynolds RTP Company Ron Miller RTP Company David Miller RTP Company Randy Nedrelo RTP Company Inspector Executive VP/General Manager VP, Information Management Commercial/Technical Officer Environmental Manager EPA Lead Inspector Signature/Date JOH N RI LEv g~,~~~;,'~:~~b~~';,~~~~o,=Ea,;,.,,meotal Protection Agency, cn=JOHN RILEY, 0.9.2342.19200300.100.1.1=68001 003655469 Date: 2023.05.30 08:50:47 -05'00' John David Riley Date Supervisor Signature/Date H STUCKEY Digitally signed by H STUCKEY Date: 2023.06.01 10:04:44 -05'00' H. Troy Stuckey Date 6ENFORM-020-R8.2 (02/12/2020) 1 Section I - INTRODUCTION RTP Company Inspection Date 03/30/2023 PURPOSE OF THE INSPECTION The purpose of this inspection is to evaluate RTP Company of Fort Worth, Texas, Federal Registry Service (FRS) Number 110000459833, 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 delegated to the states; 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 listed RTP of Ft. Worth, TX as the consignee on several imports of the chemical substance Carbon Black (Chemical Abstract Services Number [CASRN] 1333-86-4) for the years 2016, 2018, and 2019. RTP was selected for an inspection based on further comparisons with customs data for other importers/consignees of carbon black, as well as no record of prior TSCA inspections. On March 6, 2023, I, David Riley of US EPA Region 6, initially contacted the company by phone. I was called back on March 8 by Todd Reynolds, Vice President of Facilities & EHS, to discuss the focus of the inspection . On March 15, I had a phone call with Randy Nedrelo, Environmental Manager with RTP. Following the call, I sent an inspection notification email to Mr. Nedrelo. The notification included a list of information that the company should prepare for review and collection by the inspector [Appendix 1]. The inspection was scheduled for March 30, 2023. INSPECTION ENTRY & OPENING CONFERENCE I, EPA inspector David Riley, arrived at RTP's office at 9:40am on March 30, 2023. I entered the main office, proceeded to a conference room, and presented my inspector credentials to Todd Reynolds, Ron Miller, and Randy Nedrelo, all of whom are based in Winona, MN; and to David Miller, who is based in Ft. Worth. I informed all present that the inspection would involve a review and discussion of the information requested in Appendix 1. At that time, Mr. Reynolds signed the Notice of Inspection [Appendix 2] and the Inspection Confidentiality Notice [Appendix 3]. 2 COMPANY HISTORY & FACILITY DESCRIPTION RTP Company Inspection Date 03/30/2023 RTP Company's history extends back to the late 1800s. In 1923, founder Joe Miller established Miller Waste Mills, a company that processed fabric used to lubricate railroad wheels. In 1948, the company expanded into thermoset plastics with the establishment of Fiberite, which was sold to Beatrice Foods in 1980. The thermoplastics portion of the business was sold back to the Miller family in 1982 and became RTP Company (RTP = ,B.einforced Ihermof_lastics). RTP Company is headquartered in Winona, MN, and has manufacturing operations in the U.S., Mexico, Europe, and Asia. It manufactures products for various markets such as electronics, business machines, automotive, appliance, consumer, medical, sports and leisure, and industrial. The Ft. Worth, TX facility is located at 1301 Joel East Road . A warehouse is located to the west at 1125 Joel East Road. The FRS contains an additional listing for Miller Waste Mills at the 1301 address, with ID # 110034601223 Miller Waste Mills has 1,826 employees globally (2023), with sales exceeding $1 billion (2022). The RTP Company Ft. Worth facility has 146 employees (2023), with sales exceeding $124 million (2022). Section II-OBSERVATIONS DISCUSSION The inspection began with a slide presentation on company specifics, and another presentation on process flow. A thermoplastic is a plastic polymer material that becomes pliable or moldable at a certain elevated temperature and solidifies upon cooling. The facility purchases raw materials from domestic and foreign suppliers. The raw materials used are based on specifications from either RTP or the customer for critical properties of the resulting material. Carbon black adds color to the material and improves physical properties. RTP purchases carbon black from several suppliers, including Birla Carbon, which has manufacturing locations throughout the world . FACILITY TOUR At approximately 10:40am, company representatives led the inspector on a tour of the raw material receiving area, process area, and quality control/laboratories. RTP receives the dry raw material and blends it based on customer specifications. The blend is then heated and extruded, cooled, and pelletized. There are no chemical reactions occurring between the raw materials to form new chemical substances. RTP does export product to customers. 3 FACILITY DOCUMENTATION RTP Company Inspection Date 03/30/2023 No documents were collected at this time. RTP was in the process of organizing their raw material and import data in the requested format. It was agreed that RTP would keep me informed of their progress and submit the information later. The company did not have any documentation relevant to TSCA Sections 4, 5, or 8. Section Ill - AREAS OF CONCERN I observed no areas of concern at the time of the inspection. CLOSING CONFERENCE At 12:25pm, I conducted a closing conference with the company and facility representatives, indicating that I would follow up with any questions, and that an inspection report would be finalized in approximately two months. We discussed additional modifications to the deliverables specified in the inspection notification email. Company representatives did not sign the Declaration of Confidential Business Information (CBI), as they had nothing to declare [Appendix 4], but they did sign the Receipt for Samples and Documents [Appendix 5], indicating that nothing was collected. The TSCA Notice of Inspection, TSCA Inspection Confidentiality Notice, Declaration of CBI, and Receipt for Samples and Documents were then copied, and the originals were returned to me. I exited the facility at 12:55pm. Section IV - FOLLOW UP On the afternoon of 3/31/23, I received an email from Todd Reynolds with the slide presentations as attachments. On 4/11/23, I received an email from Mr. Reynolds with a summary of modifications to the deliverables listed in the original information request, based on the closing conference discussion On 4/27/23, RTP submitted raw materials information and safety data sheets (SDS) via EPA's Central Data Exchange (CDX) system. The information was identified as non-confidential. On 5/9/23, RTP submitted imports information and SDS's via EPA's Central Data Exchange (CDX) system. The information was identified as non-confidential. Some of the information gathered from the emails has been incorporated into the body of this report. 4 Section V - LIST OF APPENDICES Appendix 1- Inspection Notification Email Appendix 2 - Notice of Inspection Appendix 3 - TSCA Inspection Confidentiality Notice Appendix 4 - Declaration of Confidential Business Information Appendix 5 - Receipt for Samples and Documents RTP Company Inspection Date 03/30/2023 5 RTP Company Inspection Date: 03/30/2023 Appendix 1 Inspection Notification Email Riley, David From: Sent: To: Subject: Riley, David Wednesday, March 15, 2023 5:43 PM rnedrelo@rtpcompany.com TSCA inspection of RTP Company; Ft. Worth, TX Hello Mr. Nedrelo, This email is a follow up to our communication of March 15, 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 RTP Company facility in Ft. Worth, TX, on Thursday, March 30, 2023. 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 RTP 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 two 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 Zcalendar 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; Whether the chemical substance is Manufactured or Imported, or both; HTS Code used if imported. 1  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 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. s. 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 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); 6. Documentation Pursuant to TSCA Sections 4, 5, and 8. Provide the following documents and information, if applicable: Letters of intent to conduct testing and proof of data submittal, or requests for exemption from testing, for chemicals manufactured or used at the facility that are subject to an active TSCA Section 4 final test rule, Consent Agreement and/or test order. Records demonstrating compliance with TSCA Section 5(e)/(f) Consent Orders; Records documenting compliance with any Significant New Use Rules. Please refer to 40 C.F.R. 721.125 to ensure submission to EPA of all required information; TSCA Section 8(e) substantial risk information not known to EPA or previously submitted to EPA by your company. The TSCA Section 8(e) information includes among other items: toxicity or exposure data, full reports, summarized results, limited studies (e.g., range-finding studies), preliminary results, and draft reports that constitute sufficient evidence for Section 8(e) reporting. 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: 2 "I certify that I am fully authorized by RTP Company to provide the above information on its behalf to the U.S. Environmental Protection Agency (EPA) in response to EPA's email dated March 15, 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 Title If none of the requested information is subject to claims of confidential business information (CBI) by RTP Company, please email the information to the inspector. IfRTP 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) ofTSCA, 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)(l)(B) and 14(c)(5) ofTSCA, 15 U.S.C. 2613(c)(l)(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: 1. My company has taken reasonable measures to protect the confidentiality of the information; 3 11. I have determined that the information is not required to be disclosed or otherwise made available to the public under any other Federal law; 111. 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 1v. I have a reasonable basis to believe that the information is not readily discoverable through reverse engmeenng. 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. 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 RTP Company Inspection Date: 03/30/2023 Appendix 2 Notice of Inspection &EPA United Sta!H Env,ranmental Pn:nec.1rQn Agencv United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 Notice of Inspection Office of Enforcement and Compliance Assurance 1. Investigation Identification 3. Facility Name Date Inspection Number Daily Seq. Number IRTPCompany 'Mar 30, 2023 111 11 l of l I I 2. Inspector's Address 4. Facility Address EPA Region 6, 1201 Elm Street., Dallas, TX 75270 (Mail Code ECDST) l)ol lH-13'"Joel East Rd. Fort Worth, TX 76140 Jt> ~ 1 /1 a/1.."!> For Internal EPA Use. Copies may be provided to the recipient as acknowledgment ofthis notice. Reason for Inspection Under the authority of Section 11 ofthe 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, 1RJ processes, control and facilities) and any conveyances being used to t ransport 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 ofthe Act are applicable to the chemical substances, mixtures or articles, within, or associated with, such premise or conveyance have been complied with. ~ In addition, this inspection extends to (check. appropriate blocks): D A. Financial Data D D. Personnel Data ~ B. Sales Data D E. Research Data D C. Pricing Data The nature and extent of inspection of such data specified in A through Eabove is as follows: Inspector's Signature - //)(D(~ Name IJohn Davi;Riley Recipient's Signature I ~f'n )l . Name I I < ) ) f21Ji,,.J11/s Title !Environmental Scientist I Date 13(30It> ITitle I Jp.. ~J~F/6 I I Date, 3o~Olhazj I EPA Form 7740-3 (Rev. 2/10) 1-lnspP<:torCoP)I 2-Facllity Copy RTP Company Inspection Date: 03/30/2023 Appendix 3 TSCA Inspection Confidentiality Notice &EPA Un~odSt.tlff EnvitQnmental Protech on Age nc y United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 TSCA Inspection Confidentiality Notice Office of Enforcement and Compliance Assurance 1. Investigation Identification 4. Facility Name f--------~----------.----------1 I Date Inspection No. Daily Seq. No. RTP Company I !Mar 30, 2023 11 I 111 of 1 . ~====='.l'======== ~ =====~ 5. Address 2. Inspector's Name I.-.,.,...!I..-0-=0...,.. , - - - - - - - - - - - - - - - - - - - - , 1 ~ 1 - - - - - - - - -- - - - - - - - ~ , ll~TnelEasl'Ril FortWorth, TX 76140 John David Riley . -r ~ l'J1[.;; .,~,,.,.'t-ti~, I-=========================-! 6. Name of Chief Executive Officer .--3_ln._.;.sp_ec_to_r_Ad_d_res_s- - - - - - - - - - - - . I HV-~ ~ fv1 ;\I e (" I ~=:::::::=i:=.::::============~ US EPARegion 6, 120I Elm St, Dallas, TX 7S270 (Mail Code 7.Title ECDST) I Cf O For internal EPA use. Copies ofthis form may be provided to recipient as acknowledgment ofthis notice. To Assert a TSCA Confidential Business Information Claim ItIs possible that EPA wlll receive public requests for release ofthe information obtained during the inspection of the fadli1;y cited above. Such requests will be handled byEPA in accordance with provtslons of the Freedom oflnformation Act (fOtAJ, 5 U.S.C. 552; EPA regulations Issued thereunder, 40 C.F.R part 2; and the Toxic Substances Control Act (TSCA) Section 14 (15 U.S.C. 2613). EPAIs required to make inspection data available in response to FOIA requests unless the EPA Administrator determines that the data Is entitled to confidential treatment, or may be withheld from release under other exceptions ofFOIA. Any or all Information collected by EPA during the inspection may be daimed as confidential Ifit relates to trade secrets, commercial, or financial matters that you consider to be conflclential business information (CBI). Ifyou assert a CBI claim, EPA will disclose the information only to the extent, and by means of the procedures set forth in trn: regul;itions (cited above) governing EPA's treatment of CBL Arnonq other things, the regulations require that EPA notify you in advance ofpublidy disclosing any information clalmed as CBI. A CBI claim may be asserted at any time prior to or during the inspection. If a C8I claim is received after the inspection, EPA will make such efforts as are administratively practical to protect the infOf'IJlation. However, EPA cannot assure that such efforts will be effective In llght of the possibility ofprior disclosure. Ifit is more convenient for you to asserta CBI dalm on your own stationary or bymarking the lndivldual documents or samples "TSCA conflclential business information,' it Is not necessary for you to use this notice.The inspector will be gl ad to answer any questions you may have regarding EPA's CBI procedures. While you may claim any collected information orsampte as CBI, such claims arenotlikely to be upheld if they are challenged unless the information meets the following criteria: 1. Your company has taken measures to protect the confidentiality of the information and ft intends to continue to take such measures. 2. The Information is not, and has not been, reasonably obtainable without your company's consent by other persO!lS {other than governmental bodies), or by use of legitimate means (other1han discoverybased on showing of special needin a judicial or quasi-Judicial proceeding). 3. The informationis not publicly available elsewhere. 4. Disclosure of the Information would cause substantial harm to your company'scompetitive position. At the completlon of the inspection, you will be given a receipt forall documents, samples and other materials collected. At that time, you may make claims that some or all of the Information is CBI. Ifyou are not authorized by your company to assert a CBI claim, this notice will be sent by certified mal~ along with the receipt for documents, samples, and other materials to the Chief Executive Officer of your company within 2 days of this date. The ChiefExecutive Officermust return a statement specifying any The statement from theChiefExecutiveOfficershould beaddressedto: - - - - - - - - - - - - - - - -- - - -- - - - -- - - and mailed by registered, return-receipt requested mall within 7calendar days of receipt of this notice. Claims may be made at any time after the inspection, but the inspection data will not be entered into the TSCA/CBI security system until an official confidentiality daim Is made. The data will be handled under EPA's routlne security system unless and until a claim Is made. Ifno confidentiality claim accompanies the information when It Is received by EPA, the information may be made available to the public without further notice to the business. To Be Completed By Facility Official Receiving This Notice Iacknowledgereceipt ofthis notice: Iftt,i,re isno one on the premise who is authorized to makeCBI claims for this facility, a copy ofthis notice and otherInspection materials will be sent to the company's ChiefExecutive Officer. If there Is another official who should also receive this information, please designate below. Signature 1 ~ 1 ~ Name I I ITitle I I Title EPA Form 7740-4 (Rev. 2/16) Date 1~ ~ J?l] I Addressl l Inspector Copy 2-Facility Copy RTP Company Inspection Date: 03/30/2023 Appendix 4 Declaration of Confidential Business Information &EPA United 51~111 Environmental Protection Agency United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 Declaration of Confidential Business Information Office of Enforcement and Compliance Assurance 1. Investigation Identification 2. Company Name I I Date !Mar 30, 2023 Inspection No. 11 1 Daily Seq. No. I I of l 1IRTP Company 3. Inspector Address 4. Company Address EPA Region 6, 1201 Elm St.,Dallas, TX75270(Mail Code ~ I~oelEastRd,Fort Worth, TX 76140 ECDsn j'!)fL I For Internal EPA use.Coples ofthis form may be provided to recipient as acknowledgment ofTSCA Confidential documents described below collected in connection with the admlnistration and enforcement ofthe Toxic Substances Control Act. Information Designated as Confidential Business Information: Number Description \~ 11 ~ II ~ I ,, , ' ..,,.<) 7r I I '- I 11 I I I I I I 11 I Inspector's Signature /)b Name IJobnDavid Riley 1:1 ~ " / ' ... ; ~ '"; '-.....,..,.,..... I' " ' CO / / -~~ ' ' "'~ Claimant's Signature ] Name I ~ ~ Title !Environmental Scientist IDate13{1{'13 ITitle I loateCJ EPA Form n40-2 (Rev. 2/16) 1-lnspector Copy 2-facilltyCopy RTP Company Inspection Date: 03/30/2023 Appendix 5 Receipt for Samples and Documents oEPA Unrtd StJllat E,wironmcntal Protcciion Agency United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 Receipt for Samples and Documents Office of Enforcement and Compliance Assurance I. Investigation Identification 2. Company Name Date Inspection No. Daily Seq. No. I; jMar 30, 2023 111 \ \1 ofl 1 IRTPCompany I 3. Inspector Address ~"(pany Addres, US EPARegion 6, 1201 Elm St, Dallas, TX 75270 (Mail Code :,,'JSJoel Ea~ Rd, Fort Worth, TX 76140 ECDST) I For Internal EPA use. Copies ofthis form may be provided to recipient as acknowledgment of the documents and samples ofchemical substances and/or mixtures described below collected in connection with the administration and enforcement of the Toxlc Substances Control Act. Receipt of Document(s) and/or Sample(s) Described is Hereby Acknowledged: No. Description I ~ 11 I ~ 11 I l~/4)() 11 ~Cc;// II ~/l I' ~~~- 11 I ii ill r ~ ~ Optional: Duplicate or Split Samples: Requested and Provided Inspector's Signature Name IJohn David Riley Oaimant's Signature IName I - ~/'~ ~ ~ Not Requested I 1~ , ~ , _ ...,d~ Title !Environmental Scientist IDatel3 1~(1:, Title JP~4lc, a1~ I Date I~11~1a1JI EPA Form 77401 (Rev. 2/1 <,J 1 ln~pector Copy 2 Facility Copy