EPA?s enforcement action against Respondent arises from its failures: (a) to timely report to the Toxic
Release Inventory (TRI) for two chemicals for reporting years 2020 and 2021, and (b) to accurately
report on-site treatment methods and quantities for two other chemicals for reporting years 2018,
2019, 2020 and 2021 (EPCRA Section 313, TRI Form R violations). Respondent has certified that it is not
presently in violation of the provisions cited in the attached CAFO.