EPAs COMPLAINT ALLEGES THAT SIMONIZ WAS REQUIRED TO FILE A RISK MANAGEMENT PLAN BECAUSE IT HAS HAD MORE THAN 1000 LBS OF CONCENTRATED HYDROGEN FLUORIDE AT ITS BOLTON, CT FACILITY OVER THE LAST FIVE YEARS. ACCORDING TO THE COMPLAINT, SIMONIZ DID NOT FILE AN RMP, AND THEREBY VIOLATED CAA'S 112(R)(7). THE COMPLAINT ALSO ALLEGES THAT SIMONIZ WAS REQUIRED TO FILE TOXIC CHEMICAL RELEASE INVENTORY FORMS FOR FOUR TOXIC CHEMICALS, AND THAT ITS FAILUREÂ TO DO SO ON TIME OVER THE LAST THREE YEARS VIOLATED SECTIONS 313 OF EPCRA.