THE COMPLAINT ALLEGES THAT NORHEAST REFRIGERATED TERMINALS INC FAILED TO (a) TIMELY DEVELOP AND IMPLEMENT A RISK MANAGEMENT PLAND ( RMP ) IN ACCORDANCE WITH SECTION 103 OF CAA; (b) NOTIFY THE NATIONAL RESPONSE CENTER OF AN APRIL 18, 2004 AMMONIA RELEASE IN ACCORDANCE WITH SECTION 103 OF CERCLA; AND (c) SUBMIT TIER II FORMS IN ACCORDANCE WITH SECTION 312 OF EPCRA. THE COMPLAINT SEEKS UP TO THE STATUTORY MAXIMUM IN PENALTIES.