On September 30, 2004, EPA issued a Notice of Determination (���NOD���) based on self-disclosures provided by Cardone Industries, Inc. (���Cardone���), for violations of Sections 311 and 312 of the Emergency Planning and Community Right-to-Know Act (���EPCRA���).
In letters to EPA dated November 11, 2003, August 3, 2004, and August 10, 2004, Cardone disclosed that six (6) facilities located in Philadelphia, Pennsylvania had failed to submit Material Safety Data Sheets (���MSDS���) and Tier II reports for sulfuric acid in 2001, 2002, and 2003 to the LEPC, SERC and the local fire department. The total gravity-based civil penalty for these violations would be $61,878. However, because Cardone satisfied all of the conditions of EPA���s Self-Disclosure Policy, EPA waived the gravity-based civil penalty for the disclosed violations.