Respondent produced, used, or stored ammonia at the Facility and released a reportable quantity of an EHS, ammonia. On or about August 31, 2022, a “release” of ammonia in excess of 100 pounds occurred at the Facility (the release).
As a result of the information obtained by the EPA and subsequent investigation, the Complainant has determined that the Respondent has violated the reporting requirements of Section 304 of EPCRA and Section 103(a) of CERCLA.