On or about April 22-25, 2014, NEIC conducted an EPCRA Section 313 data quality and non-reporting inspection of Respondent's facility to determine whether Respondent was in compliance with the Toxic Chemical Release reporting requirements of 40 C.F.R. Part 372. Based on this inspection, Region 2 staff determined that Respondent failed to: (a) submit, in a timely manner, complete and correct Form R reports for 1,2,4 trimethylbenzene for the
calendar years 2010 - 2012, (b) submit, in a timely manner, complete and correct Form R reports for napthalene for the calendar years 2010 - 2012, (c) report accurate estimates of air stack releases and off-site transfers of m-cresol for calendar year 2010, (d) report accurate estimates of off-site transfers of o-cresol for calendar year 2010, (e) report accurate estimates of off-site transfers and water releases of formaldehyde for calendar year 2010, (f) report accurate estimates of off-site transfers of N-butyl alcohol for calendar year 2011, (g) report accurate estimates of water releases of formaldehyde for calendar year 2012, (h) report accurate estimates of fugitive air and air stack releases of 1,2,4 trimethylbenzene for calendar year 2013, and (i) report accurate estimates of air stack releases of ethylbenzene
for calendar year 2013.