Huntington Alloys Corporation

In June 2008, Huntington Alloys Corporation (“Huntington”) audited its facility in West Virginia and self-disclosed to EPA potential violations of the Emergency Planning and Community Right-to-Know Act (“EPCRA”) and its corresponding regulations. Subsequently, Huntington’s New Hartford, Elkhart, Burnaugh, and Dunkirk facilities, and its newly acquired addition to the West Virginia facility, Thistle Processing LLC, were audited and EPCRA violations were disclosed to EPA. Huntington has taken all appropriate corrective actions to remedy all potential violations within 60 days after receiving the independent auditor’s final audit reports in accordance with the EPA pre-approved extension, which meets the “prompt disclosure” criterion in the Audit Policy. In order to correct its EPCRA violations at its six facilities, Huntington supplied a list of extremely hazardous substances and the identity of a designated facility representation to the SERC and the LEPC. Huntington submitted Section 311 (MSDS) lists to the respective SERC, LEPC, and local fire department. Huntington submitted revised 2007 Tier II reports to the SERC, LEPC, and local fire department; revised, withdrew, and submitted new Form Rs to EPA and State agencies, and provided necessary notices to customers alerting them to the presence of EPCRA Section 313 chemicals in each product.