ON MARCH 31, 2005, EPA ISSUED A NOTICE OF DETERMINATION ( NOD ) BASED ON SELF-DISCLOSURES PROVIDED BY HUNTINGDON ALLOYS CORP FOR VIOLATIONS OF SECTION 313 OF EPCRA AT ITS FACILITY LOCATED AT 3200 RIVERSIDE DRIVE, HUNTINGTON, VIRGINIA.
HUNTINGTON DISCLOSED BY LETTER DATED OCTOBER 4, 2004 THAT IT HAD FAILED TO SUBMIT TOXIC CHEMICAL RELEASE INVENTORY FORMS (FORM R) FOR CHROMIUM AND LEAD FOR REPORTING YEAR 2003. THE TOTAL GRAVITY-BASED CIVIL PENALTY FOR THESE EPCRA VIOLATIONS WOULD BE $29,505.00. HOWEVER, BECAUSE HUNTINGTON SATISFIED ALL OF THE CONDITIONS OF EPA'S SMALL BUSINESS COMPLIANCE POLICY AND THE AMOUNT OF ECONOMIC BENEFIT GAINED ITS INSIGNIFICANT, EPA WAIVED THE CIVIL PENALTY FOR THE DISCLOSED VIOLATIONS.