Brooklyn Bottling Co. (ÂRespondentÂ) pursuant to Section 325 of the Emergency Planning and Community Right to Know Act (ÂEPCRAÂ), 42 U.S.C. Section 11045, failed to file completed emergency and hazardous chemical inventory forms (Tier I or Tier II forms as described in 40 C.F.R. Section 370.25 and 40 C.F.R. Part 370, Subpart D) to the State Emergency Response Commission (ÂSERCÂ), the Local Emergency Planning Committee (ÂLEPCÂ), and the fire department for 2002, 2003, 2004 and 2005.