1. SECTION 325 OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT -TO-KNOW ACT OF 1986 ( EPCRTKA ), 42 U.S.C. SEC. 11045. 2. PHIBRO ENERGY USA, INC. 9701 MANCHESTER AVENUE HOUSTON, TEXAS 77012 3. RESPONDENT VIOLATED SECTION 304(B) OF EPCRTKA BY 1) FAIL- ING TO PROVIDE NOTICE TO AN AFFECTED LOCAL EMERGENCY PLANNING COMMITTEE ( LEPC ) IMMEDIATELY AFTER A RELEASE OF 9,867 LBS. OF SULFER DIOXIDE ON MAR. 4, 1994, 2) FAIL- ING TO PROVIDE NOTICE TO AN AFFECTED LEPC IMMEDIATELY AF- TER A RELEASE OF 3,162 LBS. OF SULFER DIOXIDE ON JUN. 8, 1994, 3) FAILING TO PROVIDE NOTICE TO AN AFFECTED LEPC IMMEDIATELY AFTER A RELEASE OF 37,740 LBS. OF SULFER DI- OXIDE ON OCT. 18, 1994, AND 4) VIOLATED SECTION 313(A) OF EPCRTKA BY FAILING TO SUBMIT A COMPLETE AND CORRECT FORM RS TO THE RA BY JUL. 1, 1991, FOR ANTIMONY COMPOUNDS, INCLUDING ANTIMONY PENTOXIDE. 4. RELIEF SOUGHT PURSUNAT TO SECTION 325 OF EPCRTKA, EPA PROPOSES A PENALTY OF $73,250.00.