12/29/2009 - COMPLAINT FILED, PROPOSING A PENALTY OF $100,500. COMPLAINT ALLEGES: COUNT 1 - RESPONDENT FAILED TO SUBMIT COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORMS (TIER I OR TIER II) CONTAINING HYDROGEN PEROXIDE, SULFURIC ACID, ACETONE, ACETIC ACID, POTASSIUM HYDROXIDE, SODIUM HYDROXIDE, SODIUM HYDROSULFIDE, HYDROCHLORIC ACID, AND PHOSPHORIC ACID FOR CALENDAR YEAR 2007 TO THE LEPC, SERC AND FIRE DEPARTMENT WITH JURIDICTION OVER THE FACILITY BY MARCH 1, 2008. RESPONDENT VIOLATED THE REPORTING REQUIREMENTS OF SECTION 312(a) OF EPCRA FOR CALENDAR YEAR 2007.
COUNT 2 - RESPONDENT FAILED TO SUBMIT COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORMS (TIER I OR TIER II) CONTAINING HYDROGEN PEROXIDE, SULFURIC ACID, ACETONE, ACETIC ACID, POTASSIUM HYDROXIDE, SODIUM HYDROXIDE, SODIUM HYDROSULFIDE, HYDROCHLORIC ACID, AND PHOSPHORIC ACID FOR CALENDAR YEAR 2006 TO THE LEPC, SERC AND FIRE DEPARTMENT WITH JURIDICTION OVER THE FACILITY BY MARCH 1, 2007. RESPONDENT VIOLATED THE REPORTING REQUIREMENTS OF SECTION 312(a) OF EPCRA FOR CALENDAR YEAR 2006.
COUNT 3 - RESPONDENT FAILED TO SUBMIT COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORMS (TIER I OR TIER II) CONTAINING HYDROGEN PEROXIDE, SULFURIC ACID, ACETONE, ACETIC ACID, POTASSIUM HYDROXIDE, SODIUM HYDROXIDE, SODIUM HYDROSULFIDE, HYDROCHLORIC ACID, AND PHOSPHORIC ACID FOR CALENDAR YEAR 2005 TO THE LEPC, SERC AND FIRE DEPARTMENT WITH JURIDICTION OVER THE FACILITY BY MARCH 1, 2006. RESPONDENT VIOLATED THE REP