EPA alleges that Respondent, owner and/or operator of the facility at 4810 103rd Lane,
NE, Circle Pines, Minnesota, failed to include anhydrous ammonia, sulfuric acid, and ethylene
glycol on timely submitted emergency and hazardous chemical inventory form (Tier I or Tier II
form as described in 40 C.F.R. ? 370.25 and 40 C.F.R. Part 370, Subpart D) for calendar years
2019-2022, as required by Section 312 ofEPCRA, 42 U.S.C. ? 11022, and the regulations at 40
C.F.R. Part 370. Under Section 312 ofEPCRA, 42 U.S.C. ? 11022, and the regulations at 40
C.F.R. Part 370, Respondent was required to submit its Tier I or Tier II form for calendar years
2019-2022 on or before March 1, 2020, March 1, 2021, March 1, 2022, and March 1, 2023,
respectively.