ON MAY 6, 2014, EPA SENT A SHOW CAUSE LETTER TO BLEACHTECH, LLC ( RESPONDENT OR BLEACHTECH ), REGARDING EPA'S ALLEGATION THAT RESPONDENT HAD VIOLATED SECTION 103(a) OF CERCLA, SECTIONS 304 AND 312 OF EPCRA IN CONNECTION WITH CHLORINE AND SODIUM HYPOCHLORITE RELEASES FROM THE FACILITY. SPECIFICALLY, EPA ALLEGED THAT RSPONDENT VIOLATED EMERGENCY RELEASE REPORTING REQUIREMENTS AND HAD ALSO FAILED TO SUBMIT A COMPLETE AN ACCURATE HAZARDOUS CHEMICAL INVENTORY FORM FOR CALENDAR YEAR 2010 AND 2011 TO THE STATE EMERGENCY RESPONSE COMMISSION, THE LOCAL EMERGENCY PLANNING COMMITTEE FOR THE FACIITY, AND THE LOCAL FIRE DEPARTMENT. EPA AND BLEACHTECH SUBSEQUENTLY ENGAGED IN THE SETTLEMENT NEGOTIATIONS, IN WHICH RESPONDENT AGREED TO PAY THE CERCLA CIVIL PENALTY OF $54,690 AND THE EPCRA CIVIL PENALTY OF $95,310 FOR CASH PENALTY OF $150,000, AND CONSTRUCT AND IMPLEMENT A SUPPLEMENTAL ENVIRONMENTAL PROJECT ( SEP ) WHICH WILL COST: AN INITIAL ONE TIME CAPTIAL EXPENDITURE OF $75,000 AND A RECURRING EXPENSE OF $7,000 PER YEAR, FOR A FIVE-YEAR PERIOD.