ON SEPTEMBER 18, 2017, EPA ISSUED A NOD PURSUANT TO THE SELF DISCLOSURE POLICY, AS SUPPLEMENTED BY THE NEW OWNER POLICY, TO BRENNTAG NORTH AMERICA, INC. ( BRENNTAG ) AND BWE, LLC ( BWE ). THE NOD RESOLVES VIOLATIONS OF SECTION 313 OF EPCRA THAT OCCURRED AT THE FACILITY LOCATED AT 201 LOCUST STREET, BUILDING D, YOUNGWOOD, PENNSYLVANIA ( FACILITY ). UNDER SECTION 313 OF EPCRA, CERTAIN BUSINESSES ARE REQUIRED TO SUBMIT REPORTS EACH YEAR CONTAINING THE AMOUNTS OF TOXIC CHEMICALS THEIR FACILITIES RELEASE INTO THE ENVIRONMENT, EITHER ROUTINELY OR AS A RESULT OF ACCIDENTS. THE PURPOSE OF THIS REPORTING REQUIREMENT IS TO INFORM GOVERNMENT OFFICIALS AND THE PUBLIC ABOUT RELEASES OF TOXIC CHEMICAL. SECTION 313 REQUIRES FACILITIES TO REPORT RELEASES TO AIR, WATER, AND LAND. IN A LETTER TO EPA, DATED FEBRUARY 17, 2017, BRENNTAG AND BWE DISCLOSED THAT THE FACILITY HAD FAILED TO SUBMIT THE REQUIRED FORMS Rs TO EPA FOR ZINC COMPOUNDS MANUFACTURED AT ITS FACILITY DURING THE REPORTING YEARS FOR 2012-2015. THE TOTAL GRAVITY-BASED CIVIL PENALTY FOR THESE VIOLATIONS, CALCULATED IN ACCORDANCE WITH EPA PENALTY POLICIES, WOULD BE $22,336. HOWEVER, THE BRENNTAG AND BWE SATISFIED ALL OF THE CONDITIONS OF EPA'S SELF DISCLOSURE POLICY AND NEW OWNER POLICY AND THE AMOUNT OF ECONOMIC BENEFIT GAINEED WAS INSIGNIFICANT; THEREFORE, EPA WAIVED THE GRAVITY-BASED CIVIL PENALTY FOR THE DISCLOSED VIOLATIONS. THE COMMONWEALTH OF PENNSYLVANIA WAS NOT INVOLVED IN THIS CASE.