A complaint was filed by USEPA for violations and assessment of civil penalties pursuant to Section 112(r) of the Clean Air Act and Section 312 of EPCRA. Under Section 112(r)(7) of the Clean Air Act and Section 312 of EPCRA, Fluoro-Seal processed, handled and stored hydrogen fluoride at its facilities greater than 1,000 pounds at its St. Louis and Centerville facilities. Respondent did not develop and implement a risk management program for its Mt. Pleasant Iowa; Kansas City, Missouri; St. Louis, Missouri; and Centreville Iowa facilities as required by Section 112 (r)(7). Respondent also failed to submit a completed emergency and hazardous chemical inventory form to the SERC and LEPC during various years for these facilities for aluminum oxide, whose threshold level is 10,000 pounds. These are violations of Section 312 of EPCRA.