On November 10, 2015, the USEPA conducted an on-site inspection at the facility to determine regulatory compliance regarding the filing of Toxic Chemical Release Inventory (TRI) Form A or Form R reports under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). Based on documents reviewed during and post-inspection, it appears that the company was required to file a TRI Form R report for dichloromethane for each of calendar years 2012, 2013 and 2014 as detailed in the table below. Each failure to submit a Form A or R report, in a
timely manner constitutes a violation of Section 313 of EPCRA, 42 U.S.C. 11023, and of 40 C.F.R. 372.30. The final penalty was $15,045.