THE EPCRA SECTION 312 AND 313 REFERRAL TO DOJ ENCOMPASSES THE EPCRA SECTION 312 AND 313 CLAIMS ALLEGED IN EPA REGION VII'S ADMINISTRATIVE COMPLAINT DATED MARCH 29, 1996. EPA REGION VII PREVIOUSLY SENT LITIGATION REPORTS TO DOJ PERTAINING TO VIOLATIONS OF THE CAA 112(R), CERCLA 103, AND EPCRA 304 ARISING OUT OF AN EXPLOSION AT THE TERRA FACILITY ON DECEMBER 13, 1994, AND FOR CERCLA COST RECOVERY CLAIMS INCURRED. SUBSEQUENT TO THOSE PRIOR LITIGATION REPORTS, TERRA AND THE U.S. REACHED A SETTLEMENT-IN-PRINCIPLE ON ALL OUTSTANDING CLAIMS AGAINST TERRA, INCLUDING THE EPCRA SECION 312 AND 313 ADMINISTRATIVE ACTION PENDING IN REGION VII. BECAUSE ALL CLAIMS HAVE BEEN NEGOTIATED TOGETHER FOR SETTLEMENT PURPOSES, REGION VII IS REFERRING THE EPCRA SECTION 312 AND 313 VIOLATIONS FOR INCLUSION IN THE COMPLAINT TO BE FILED SIMULTANEOUSLY WITH THE LODGING OF THE CONSENT DECR