The facility failed to file timely Toxic Release Inventory Form R reports for lead for each of calendar years 2004, 2005, 2006 and 2007 as required under Section 313 of the Emergency Community Right to Know Act.
The amended complaint deletes the count for the failure to file in a timely manner for lead for 2004 due to the Statute of Limitations, adds counts for the failure to file in a timely manner for antimony for 2006 and 2007, and adds data quality counts for lead for years 2008 and 2009.