On or about June 17, 2014 and on June 18, 2015, EPA, Region 2 personnel conducted an EPCRA Section 313 data quality and non-reporting inspection of Respondent?s facility to determine whether Respondent was in compliance with the Toxic Chemical Release reporting requirements of 40 C.F.R. Part 372. Based on this inspection, Region 2 staff determined that Respondent had failed to file Form R reports for tetrabromobisphenol A, a listed TRI chemical,
for each of calendar years 2010, 2011, 2012, and 2013.