AN ADMINISTRATIVE COMPLAINT ALLEGING VIOLATIONS OF SECTION 103 OF CERCLA, 42 U.S.C. SECTION 9603, BY KOPPERS INDUSTRIES ( KOPPERS OR RESPONDENTS ) WAS ISSUED BY EPA REGION III ON JUNE 25, 2001. THE COMPLAINT ALLEGES THAT AT 9:00AM ON AUGUST 27, 1996, A RELEASE OF NAPTHALENE, WHICH IS A CERCLA HAZARDOUS SUBSTANCE, GREATER THAN ITS REPORTABLE QUANTITY OF 100 POUNDS, OCCURRED FROM KOPPERS FOLLANSBEE FACILITY, FOLLANSBEE, WEST VIRGINIA. IN ADDITION, THE COMPLAINT ALLEGES THAT A 10:45 AM ON JANUARY 11, 1997, BETWEEN 200 AND 300 POUNDS OF O-TOLUIDINE WAS RELEASED AT THE FACILITY. THE NRC WAS NOT INFORMED OF THE RELEASES UNTIL APPROXIMATELY 1 HOUR AND 20 MINUTES AND 48 HOURS RESPECTIVELY AFTER IT IS ALLEGED THAT KOPPERS HAD KNOWLEDGE THAT A RELEASE EXCEEDING THE RQ OCCURRED, IN VIOLATION OF SECTION 103 OF CERCLA. THE TOTAL PROPOSED PENALTY IS $31,250.00.