Entegris, Inc. spent nearly three years pumping hazardous air pollutants into the skies above Chester, Pennsylvania, one of the most environmentally devastated cities in the entire state, and the federal government’s final answer was a fine smaller than the annual salary of a public school teacher.

What Money Cannot Repay

Chester, Pennsylvania is not a random dot on a map. It sits in Delaware County, a city that environmental justice researchers have documented for decades as one of the most pollution-burdened communities in the entire state. The residents of Chester are overwhelmingly Black and low-income. They already breathe some of the worst air in Pennsylvania before you add a specialty chemical plant running hazardous feedstocks without monitoring, without records, and without telling anyone.

Ethylene dichloride and methylene chloride are not minor irritants. Ethylene dichloride is a probable human carcinogen per the EPA’s own classifications, linked to liver damage and cancer. Methylene chloride is a known carcinogen associated with liver cancer, lung cancer, and neurological damage. The federal government specifically included both chemicals on the list of compounds requiring tight monitoring and reporting under the Chemical Manufacturing National Emission Standards for Hazardous Air Pollutants precisely because they threaten human health in urban communities.

Entegris started using ethylene dichloride as a feedstock no later than January 27, 2021. It started using methylene chloride no later than February 9, 2021. The first compliance report was legally due by April 27, 2021. Entegris filed no report. The EPA physically showed up and inspected the plant on August 31, 2021. Entegris still filed no report. The company kept using methylene chloride until December 11, 2023, more than two and a half years after the very first deadline it missed.

The people who live near 800 W. Front Street in Chester did not get a notice. They did not get a choice. They did not get a warning that a specialty chemical company nearby was using cancer-linked industrial chemicals and had decided, for reasons never explained in the public record, to simply skip the paperwork that would have triggered oversight of those emissions. They breathed the air and went about their lives, unaware that the legal safeguards designed to protect them were sitting in a filing cabinet that no one at Entegris bothered to fill out.

The record-keeping violations compound the harm. The Chemical Manufacturing standards required Entegris to conduct quarterly inspections of process vessels, to check heat exchange systems for hydrocarbon leaks, and to track exactly how much organic hazardous air pollutants were being emitted or used in each batch process. Entegris kept none of these records from at least January 27, 2021 through December 11, 2023. That means there is no paper trail. There is no way for regulators, researchers, or residents to go back and reconstruct what actually came out of that plant and in what quantities. The community’s exposure history has been erased by the company’s own negligence.

Straight From the Document: No Spin Needed

“Beginning no later than January 27, 2021 and on multiple occasions through October 24, 2022, the CMPUs at Respondent’s Facility used as feedstock materials that contained the organic compound ethylene dichloride at individual concentrations greater than 0.1 percent by weight.” EPA Consent Agreement, Paragraph 31

“Beginning no later than February 9, 2021 and on multiple occasions through December 11, 2023, the CMPUs at Respondent’s Facility used as feedstock materials that contained the organic compound methylene chloride at individual concentrations greater than 0.1 percent by weight.” EPA Consent Agreement, Paragraph 32

“At all timed relevant to the violations alleged herein, Respondent failed to submit any Chemical Manufacturing NESHAP Notifications of Compliance Status in connection with the use of ethylene dichloride and methylene chloride in its CMPUs at the Facility.” EPA Consent Agreement, Paragraph 34

“From at least January 27, 2021 through December 11, 2023, Respondent failed to keep records required by 40 C.F.R. § 63.11501(c)(1).” EPA Consent Agreement, Paragraph 38

“Respondent neither admits nor denies the specific factual allegations set forth in this Consent Agreement.” EPA Consent Agreement, Paragraph 6

Who Actually Pays the Price

Public Health: Chemicals the EPA Calls Threats to Urban Communities

The EPA does not regulate ethylene dichloride and methylene chloride because bureaucrats like paperwork. It regulates them because Congress specifically directed the agency, in Section 112(k)(3)(B) of the Clean Air Act, to identify the hazardous air pollutants that pose the greatest threat to public health in the largest number of urban areas. Both of these chemicals ended up on that list of 30 priority urban hazardous air pollutants.

Methylene chloride is a solvent and chemical intermediate that the EPA has classified as a likely human carcinogen. It metabolizes in the body into carbon monoxide and formaldehyde. Long-term exposure connects to liver cancer, lung cancer, and central nervous system damage. Ethylene dichloride is used as an industrial chemical precursor and carries a probable human carcinogen classification, with documented links to cancer of multiple organ systems. These are the chemicals Entegris was running through its Chester plant with no monitoring records and no regulatory notifications.

The absence of records matters clinically as well as legally. Without Entegris’s batch records, emissions calculations, heat exchanger inspection logs, or process vessel inspection data, public health researchers and community advocates have no baseline. They cannot demonstrate elevated exposure. They cannot connect a spike in illness to a specific period of operation. The company’s failure to keep records is not a bureaucratic inconvenience; it functions as a shield against accountability for whatever health consequences may follow.

Economic Inequality: A Fine That Costs Less Than a Luxury Car

Entegris, Inc. is a Delaware corporation headquartered in Billerica, Massachusetts. It is a specialty chemicals and materials company that supplies the semiconductor industry, one of the most profitable industrial sectors in the global economy. The company’s corporate revenue dwarfs the penalty imposed here by orders of magnitude. The EPA’s own penalty calculation framework required the agency to consider “the economic benefit of noncompliance,” meaning it tried to calculate how much money Entegris saved by skipping the compliance work it was legally required to do.

The final penalty of $55,421 (roughly what a full-time warehouse worker earns over two years) represents the government’s total financial response to nearly three years of Clean Air Act violations at a plant in an environmental justice community. The penalty is not large enough to register as a line item in a company of Entegris’s scale. It does not recapture the economic benefit of noncompliance. It does not compensate Chester residents for any exposure. It does not fund any monitoring, testing, or health services for the community.

The structure of the consent agreement itself reveals the power imbalance. Entegris hired Squire Patton Boggs, a global law firm with offices in 47 countries, to represent it. Entegris bears its own attorney fees under the agreement. For a corporation that can afford Squire Patton Boggs, $55,421 is the cost of a rounding error on the legal bill.

The Fine, Broken Down

Who Signed This. What You Can Do.

Who Signed the Agreement on Behalf of Entegris

• Joe Colella, Senior Vice President, Entegris, Inc. — signed the Consent Agreement on May 14, 2025, legally binding the company to its terms.

Regulatory Bodies with Jurisdiction and Oversight Power

• U.S. EPA Region 3 (Philadelphia) — the agency that brought and settled this case. It retains the right to pursue additional action if it identifies imminent and substantial endangerment to public health or the environment.
• U.S. EPA Enforcement and Compliance Assurance Division — the division that monitors compliance with the Final Order going forward.
• Pennsylvania Department of Environmental Protection (PA DEP) — the state agency with parallel authority to regulate air emissions from the Chester facility under state law.
• U.S. Department of Justice — expressly authorized under the Final Order to pursue civil action if Entegris fails to pay or comply with the agreement’s terms.

Watchlist: What the EPA Explicitly Kept Open

The Final Order contains a crucial reservation of rights. The EPA stated it retains authority to “commence action against any person, including Respondent, in response to any condition which the EPA determines may present an imminent and substantial endangerment to the public health, public welfare, or the environment.” This settlement closes only the specific penalty claims for the two counts alleged. It does not close the door on further enforcement.

What Everyday People Can Do Right Now

If you live in or near Chester, Pennsylvania: Contact the Clean Air Council (cleanair.org), an advocacy organization that tracks industrial air pollution across Pennsylvania and provides resources to residents who believe they are affected by illegal emissions. Reach out to PA DEP and demand that the state conduct its own independent inspection of the Entegris facility at 800 W. Front Street.

For everyone else: File public comments with the EPA when consent agreements involving environmental justice communities are open for public review. The structure of these settlements, small fines, no admission of wrongdoing, no remediation funding, is a policy choice that gets made in part based on how much public pressure exists. Support the work of local environmental justice organizations in Chester and in your own city. Mutual aid networks in communities like Chester frequently do the monitoring, the data collection, and the organizing that underfunded regulators do not. Fund them. Show up for them.