The violations that are the subject of this NOD were voluntarily disclosed by Arctic to EPA by letters dated April 30, 2004, and July 16, 2004.
Arctic disclosed to EPA violations of the Emergency Planning and Community Right-to-Know Act (EPCRA) as follows:
(a) For ten (10) facilities in Iowa, Kansas, Nebraska, Minnesota, and Pennsylvania for Failure to submit a Material Data Safety Sheet (MSDS) report as required by the Emergency Planning and Community Right-to-Know Act (EPCRA) ?311 and 40 C.F.R. 370.20.
(b) For ten (10) facilities in Iowa, Kansas, Nebraska, Minnesota, and Pennsylvania for Failure to submit a Tier II report as required by EPCRA ?312, and 40 C.F.R. 370.25.