ON FEBRUARY 3, 1997, U.S. EPA ISSUED A PREFILING NOTICE LETTER TO BFI DECLARING U.S. EPA'S INTENT TO FILE A COMPLAINT ALLEGING VIOLATIONS OF EPCRA SECTION 312 FOR BFI'S FAILURE TO FILE COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORMS ( TIER FORM ) FOR ANHYDROUS AMMONIA WITH THE RELEVANT STATE EMERGENCY PLANNING COMMISSION AND LOCAL EMERGENCY PLANNING COMMITTEE FOR CALENDAR YEAR 1994. BECAUSE BFI'S SIC CODE DESIGNATED IT AS A FOOD AND KINDRED PRODUCTS BUSINESS ENTITY, BRI WAS EXTENDED THE BENEFIT OF U.S. EPA'S NATIONAL EPCRA SECTION 312 SECTOR ENFORCEMENT AGREEMENT INITIATIVE (THE INITIATIVE ). U.S. EPA OPERATES THE INITIATIVE TO ENHANCE EPCRA COMPLIANCE IN THE FOOD AND KINDRED PRODUCTS INDUSTRY. ALTHOUGH BFI COULD NOT HAVE TAKEN ADVANTAGE OF THE INITIATIVE BECAUSE OF U.S. EPA'S INSPECTION DISCOVERING BFI'S VIOLATIONS PREDATED THE INITIATIVE, THE INITIATIVE EQUIVALENT WAS EXTENDED TO BFI DUE TO EQUITY CONSIDERATIONS. UNDER THE TERMS OF THE INITIATIVE, ALL OF BFI'S VIOLATIONS WOULD SETTLE FOR $2,000. PENALTY PAID IN FULL 7/31/97. RESPONDENT COMPLIED WITH ALL ORDER REQUIREMENTS: 7/31/97