With respect to consolidation, the Board notes that after
having been denied consolidation by the Board early in theproceedings, the parties sidestepped the Board’s denial by simplyadopting the record in the enforcement.
Furthermore, the record supports that a cease and
desist order with respect to the phenol excursions “would imposean arbitrary and unreasonable hardship~” The subsequent compliance program contained in the Board Order, an often ased...
Allowed
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