This action was taken pursuant to an off-site record review. A review of the Toxic Release Inventory Envirofacts Database (TRI Database) indicated the following violations:
CHEMICAL YEAR POUNDS PROCESSED DUE DATE POSTMARK DATE DAYS LATE
Di(2-Ethylhexyl) Phthlate (DEHP) 2001 39,930 Lbs. July 1, 2002 May 22, 2007 > 1 yr
Di(2-Ethylhexyl) Phthlate (DEHP) 2002 36,626 Lbs. July 1, 2003 May 22, 2007 > 1 yr
Di(2-Ethylhexyl) Phthlate (DEHP) 2003 43,734 Lbs. July 1, 2004 May 22, 2007 > 1 yr
On December 27, 2006, a showcause letter addressing the above late reporting violations was sent to the company in an effort to gain more insight into the circumstances concerning the violations. The failure to submit the Form R in a timely manner constitutes a violation of Section 313 of EPCRA, 42 U.S.C. §11023, and 40 C.F.R §372.30.