ON JUNE 19, 1998, REGION 5 FILED A COMPLAINT IN THIS MATTER AGAINST OLIN CORPORATION PURSUANT TO SECTION 325 OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT ( EPCRA ) 42 U.S.C. 11045. THE COMPLAINT ALLEGED THAT OLIN CORPORATION COMMITTED THE FOLLOWING VIOLATIONS OF EPCRA: 1) OLIN CORP. FAILED TO IMMEDIATELY NOTIFY THE INDIANA STATE EMERGENCY RESPONSE COMMISSION OF A RELEASE OF PROPYLENE OXIDE GREATER THAN OR EQUAL TO ITS REPORTABLE QUANTITY, WHICH OCCURRED ON JANUARY 15, 1997, IN VIOLATION OF EPCRA SECTION 304(A); 2) OLIN CORP. FAILED TO NOTIFY THE VANDERBURG COUNTY LOCAL EMERGENCY PLANNING COMMITTEE OF A RELASE OF PROPYLENE OXIDE GREATER THAN OR EQUAL TO ITS REPORTABLE QUANTITY, WHICH OCCURRED ON JANUARY 15, 1997, IN VIOLATION OF EPCRA SECTION 304(A); 3) OLIN CORP. FAILED TO PROVIDE WRITTEN FOLLOW-UP NOTICE TO THE INDIANA STATE EMERGENCY RESPONSE COMMISSION AS SOON AS PRACTICABLE AFTER A RELEASE OF PROPYLENE OXIDE GREATHER THAN ITS REPORTABLE QUANTITY, WHICH OCCURRED ON JANUARY 15, 1997, IN VIOLATION OF EPCRA SECTION 304(C); AND 4) OLIN CORP. FAILED TO PROVIDE A WRITTEN FOLLOW-UP NOTICE TO THE VANDER- BURG COUNTY LOCAL EMERGENCY PLANNING COMMITTEE AS SOON AS PRACTICABLE AFTER A RELEASE OF PROPYLENE OXIDE EQUAL TO OR GREATER THAN ITS REPORTABLE QUANTITY, WHICH OCCURRED ON JANUARY 15, 1997, IN VIOLATION OF EPCRA SECTION 304(C). ON APRIL 6, 1999, REGION 5 ENTERED