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In addition to [lie requirements of 40 CFR Part 82 Subpart F. Consolidated should be <br />aware of requirements for importers of used controlled substances, (e.g., used class I or class Il <br />oyone-depleting substances such as R-12 and R-22) which were published as part of (lie <br />amendments to the accelerated phaseout regulations of Subpart A. Importers of used controlled <br />substances must submit a petition to EPA at least 40 working -days before the shipment is to <br />leave the country of export. As part of the petitioning process, the importer must document the <br />previous use and ownership of the material. If the shipment is approved by both the government <br />representing the country of origin and EPA, the petitioner will be issued a non -objection notice. <br />If a representative of Consolidated knowingly buys or possesses controlled substances <br />CFCs, HCFCs, methyl bromide, fmalons, methyl chloroform, etc.) that were illegally <br />imported into the United Slates, Consolidated is committing a punishable criminal oflense. <br />Consolidated should be able to describe the diligent efforts taken to make sure that the controlled <br />substances in its possession have not been illegally imported. EPA suggests that Consolidated <br />representatives ask potential suppliers of used controlled substances for documentation of prior <br />ownership and the typc(s) of equipment from which the substance was recovered. If you believe <br />that the substance was imported, we suggest that you ask for the non -objection notice or other <br />Forms of import authorization from EPA. These precautions will help to ensure that you do not <br />become a handler of illegally imported ozone-depleting substances. EPA or U.S. Customs and <br />Border Protection, under its laws and regulations, may confiscate any goods that enter the United <br />States illegally. Confiscation can occur anywhere throughout time distribution chain. <br />If at any time Consolidated fails to comply with the above requirements or with any of the <br />provisions of40 CFR Part 82, the Administrator reserves (lie right to revoke your refrigerant <br />reclaimer certification. <br />Thank you for your interest in reclaiming used refrigerant. If you have any questions, <br />please contact Julius Banks of illy staff at (202) 343-9870. <br />Sincerely, <br />Ross Brennan, Chief <br />Office of Atmospheric Programs <br />Stratospheric Protection Division <br />Stratospheric Program Implementation Branch <br />RECEIVED <br />MAY 18 2015 <br />ENVIRONMENTAL <br />