THE FACILITY SENT A LETTER DATED JANUARY 12, 2000, DISCLOS- ING POTENTIAL VIOLATIONS OF THE EMERGENCY PLANNING COMMUNITY RIGHT-TO-KNOW ACTION SECTION 312, IN THAT THE FACILITY HAD MORE THAN THE MINIMUM THRESHOLD LEVEL OF 500 POUNDS OF ANHYDROUS AMMONIA AND DID NOT SUBMIT FOR CALENDAR YEAR 1999. THE FACILITY IS CHECKING FOR PAST YEARS NON COMPLIANCE. THE FACILITY FAILED TO SUBMIT THE EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORMS TO THE STATE EMERGENCY RESPONSE COMMISSION (SERC) AND THE LOCAL EMERGENCY PLANNING COMMITTEE BY THE MARCH 1 DEADLINE, FOR CALENDAR YEARS 1994-1998. U.S. EPA INSPECTED THE FACILITY FOR EPCRA COMPLIANCE IN DECEMBER 1995 AND SENT THEM A WARNING LETTER IN JULY 1996. THE SERC SENT THE FACILITY A LETTER IN SEPTEMBER 1998 BASED ON THE FACT THE FACILITY HAD NOT REPORTED UNDER EPCRA SECT- ION 312 TO THE SERC FOR CALENDAR YEAR 1997. U.S. EPA RE- VIEWED THE INFORMATION AND DETERMINED THAT THIS FACILITY HAS A HISTORY OF PROPERLY REPORTING.