ON SEPTEMBER 30, 2014, EPA FILED A CONSENT AGREEMENT AND FINAL ORDER, WHICH INITIATED AND SETTLED EPA'S PENALTY CLAIM FOR VIOLATION OF CERCLA SECTION 103, IN CONNECTION WITH A RELEASE OF SODIUM DIOXIDE THAT OCCURRED ON APRIL 12, 2013, AND VIOLATION OF EPCRA SECTIONS 311 AND 312. EPA ALLEGED IN THE CONSENT AGREEMENT THAT THE RESPONDENT FAILED TO IMMEDIATELY NOTIFY THE NATIONAL RESPONSE CENTER FOLLOWING THE RELEASE OF SODIUM HYDROXIDE INTO THE ENVIRONMENT FROM RESPONDENT'S FACILITY LOCATED AT 2230 WYATTS MILL ROAD IN JARRATT, VIRGINIA. EPA HAS ALLEDGED THAT RESPONDENT VIOLATED SECTION 311 OF EPCRA BY FAILING TO SUBMIT TO THE SERC, LEPC, AND LOCAL FIRE DEPARTMENT EITHER MSDS FOR TWO HAZARDOUS CHEMICALS, A-222 AND A342, OR A LIST INCLUDING THE HAZARDOUS CHEMICALS, PRESENT AT THE FACILITY IN QUANTITIES EQUIP TO OR EXCEEDING THEIR RESPECTIVE THRESHOLDS NO LATER THAN THREE (3) MONTHS AFTER THE CHEMICALS WERE PRESENT AT THE FACILITY; AND THAT THE RESPONDENT VIOLATED EPCRA SECTION 312 BY FAILING TO SUBMIT TO THE SERC, LEPC, AND LOCAL FIRE DEPARTMENT A COMPLETE AND ACCURATE CHEMICAL INVENTORY FORM FOR THE FACILITY CALENDAR YEARS 2010, 2011, AND 2012 IDENTIFYING THE TOTAL QUANTITY OF LEAD ACID BATTERY PRESENT AT THE FACILITY DURING THOSE CALENDAR YEARS.