On March 22, 2011, Sidera voluntarily disclosed potential violations at seven facilities where it stores diesel fuel andlor batteries containing sulfuric acid. Sidera failed to accurately and completely file Tier I1 reports
as required by Section 312 of EPCRA, 42 U.S.C. § 11022, and 40 C.F.R. 5 370.25. Sidera filed
the required EPCRA Tier I1 reports to the appropriate SERCs, LEPCs, and local fire
departments, within 60 days of discovery. Relying on the facts and statements presented in the
attached correspondence, EPA has determined that these disclosures meet the conditions of the
Audit Policy, and that no further action nor assessment of civil penalties is required.