United Slates
Environmental Protection
Agency
Solid Waste
and Emergency
Response (OS-120)
September 1991
OS WER-91-009.1
&EPA Making It Work
III Compliance
Hazardous
chemicals are a
fact of life for
every community in the
United States. In
recognition of that hazard,
the Emergency Planning
and Community Right-to-
Know Act (commonly
known as EPCRA or Title
III) was passed in 1986.
Building upon EPA's
Chemical Emergency
Preparedness Program and
existing state and local
efforts, the new law
required facilities to report
on the presence and release
of hazardous chemicals in
their communities. This
helps state, tribal, and local
governments prepare for,
respond to, and prevent
chemical emergencies. It
also makes state and local
government officials
partners with industry,
working to protect public
health and the environment.
Under Title IE, facilities are
required to provide
information about on-site
hazardous chemicals, to
report chemical releases,
and to work with local
officials responsible for
emergency planning (see
page 6). These reporting
requirements are central to
Title Ill's goal of improving
local emergency
preparedness and increasing
community awareness of
chemical hazards.
THE PUBLIC'S
RIGHT-TO-KNOW
Since Title III became law,
LEPCs across the country
have spent much time and
energy identifying the
chemical hazards in their
communities. To a large
extent, their work has
increased the safety of
emergency responders as
well as others in the
community. Yet many
facilities still expose
emergency responders and
the general public to
needless risks. The reason?
Facilities often don't
provide the required
information to local
officials on chemical
identity, use, and storage.
The quality of local
emergency planning is
What's Inside....
The Making It Work bulletins are intended to provide
technical assistance to those responsible for
implementing the Emergency Planning and Community
Right-to-Know Act of 1986, commonly known as
EPCRA or Title III.
Title III Compliance, the first in the series, is intended
for members of LocalEmergency Planning Committees
(LEPCs), State Emergency Response Commissions
(SERCs), fire departments, and other agencies
responsible for emergency planning and Title III
compliance. Future bulletins will cover such subjects as
hazards analysis, SERC operations, and funding.
Inside you'll find practical information on Tide III
compliance, with examples drawn from successful or
unique state and local programs. If you know of other
innovative Title III implementation programs, we'd like
to hear about them. Contact your EPA Regional Title III
office (see page 7) or the Emergency Planning and
Community Right-to-Know Information Hotline at 800-
535-0202 or 703-920-9877.
compromised by this
missing information.
Improving the track record
of industry compliance with
Title HI involves three
basic elements:
• Identifying facilities
potentially subject to
Tifle HI;
• Informing tfiose facilities
of their legal
requirements; and
• Enforcing the
requirements.
The first element is to
identify those facilities mat
must report under Title III,
whether they fall under
section 302 planning
requirements, section 304
notification requirements,
or sections 311 and 312
hazardous chemical
inventory reporting
requirements, or section
313 toxic chemical release
reporting requirements.
After the facilities are
identified, they must be
made aware of their
responsibilities under Title
III. If the businesses don't
comply voluntarily, LEPCs
and SERCs, in consultation
with EPA, may enforce the
requirements through civil
or criminal suits. •
Printed on Recycled Paper
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MAKING
WORK
Identifying
facilities subject to
Emergency
Planning and Community
Right-to-Know Act
(commonly known as
EPCRA or Title JII)
regulations isn't always an
easy task. There's no
foolproof, sure-fire method
for identifying all the
businesses that handle
hazardous chemicals in a
community, but existing
databases and other
information resources make
the task easier (see boxes
below and on page 4).
Finding out who's handling
hazardous chemicals in
your community can be
time-consuming, but it's a
critical first step that makes
the task of improving
compliance much simpler.
And by creating a
comprehensive database of
chemical facilities and
DETERMINING
WHO'S
COVERED
updating it regularly, you'll
have a basic organizational
framework in place.
LEPCs and SERCs around
the country have discovered
creative ways to identify
facilities subject to Title in
regulations. The
Washtenaw County,
Michigan, LEPC, for
example, examined lists of
federal permittees covered
by the Resource
Conservation and Recovery
Act (RCRA) and the Clean
Air Act By using these
existing lists that are
available from the state
environmental agency, the
LEPC saved both time and
resources. Other easily
accessible community
resources include tax
records, business permits,
hazardous waste permits,
utility records, fire
inspection records, and the
collective knowledge of
police, firefighters, and
other LEPC members.
The Wyandotte County,
Kansas, LEPC took a
broad-based approach by
placing notices in the
annual business tax bills of
4,200 facilities with
occupational licenses. The
LEPC also made public
Who Uses What Chemicals?
To help answer this question, EPA has developed a cross-listing of Standard Industrial
Classification (SIC) codes, which identifies the type of business activity occurring at a
facility, and the Title III section 302 extremely hazardous substances (EHSs). This list,
together with county or city information on local businesses, can help identify facilities
that may be required to report. LEPCs can use this information to identify which types
of facilities are likely to use hazardous substances covered under Title III.
This documenL A Guide to Chemical Use in Industry; Extremely Hazardous Chemical/
Standard Industrial Classification Code Crosswalks for the Emergency Planning and
Community Right-to-Know Act fEPCRAX (March 29,1989) was developed by EPA's
Office of Waste Programs Enforcement. To obtain a copy, please write:
Emergency Planning
& Community Right-to-Know Information Service
U.S.EPA(OS-120)
401 M Street, S.W.
Washington, DC 20460
service announcements on
radio and TV; identified
potentially regulated
businesses from
approximately 40
categories of facilities
subject to a newly adopted
Uniform Fire Code; and
mailed a screening survey
to facilities that had
requested information
about the storage of
hazardous chemicals.
A-1 Chemical
I AAA Chemical
ABC Chlorine
| ACME Ammonia
American Chemical!
Atlantic Refining
Atlas Chemical
Some SERCs and LEPCs
have found that it's
possible to discover
violators when
investigating chemical
emergencies or significant
releases. Always be on the
lookout for new ideas.
There are plenty of
untapped resources within
easy access, starting with
the telephone book—the
most accessible list of
businesses in your
community. •
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MAKING
WORK
For companies, as
well as for
individuals,
ignorance is no defense
when it comes to breaking
the law. The 1947 Supreme
Court decision, Federal
Corp Insurance Corp. v.
Merrill, stated that
"everyone is charged with
knowledge of the United
States Statutes at large."
This means facility
operators can't claim
ignorance of Emergency
Planning and Community
Right-to-Know Act
(commonly known as
EPCRA or Title III)
requirements as an excuse
for non-compliance.
Even so, the more
information companies
have, the more likely they
are to comply. LEPCs have
used many successful
methods for reaching and
educating businesses
potentially subject to Title
III, from publishing their
own booklets to working
with local media.
IGNORANCE
IS NO DEFENSE
Some LEPCs have worked
with local trade
associations to target
specific classes of •
businesses likely to be
subject to the law. To
encourage compliance in
New York City, for
example, the LEPC
identified more than 100
trade associations whose
members might be subject
to regulation. The LEPC
worked with the New York
Sanitary Suppliers, the
Association of Graphic
Arts, and other associations
to develop mailings and
presentations on
community right-to-know
issues. The New York City
LEPC also offered
compliance workshops for
the numerous municipal
agencies whose facilities
might be subject to Title
III. These presentations
and workshops have
resulted in significant
numbers of facility
submissions.
In Racine County,
Wisconsin, the LEPC
focused their efforts on
farms that were using
extremely hazardous
substances (EHSs) listed in
section 302. When the
LEPC received a list of
potentially covered
facilities from the SERC,
the LEPC realized that a
number of facilities known
to have EHSs above the
threshold planning quantity
were missing from the list.
Only a few farms had
reported, yet the LEPC
members indicated that
approximately 100 farms in
the area would be covered
under the emergency
planning requirements of
section 302.
Because list of EHSs did
not readily translate into the
kind of information farmers
could understand (i.e., on
product labels), a dedicated
group of Racine County
LEPC members identified
66 EHSs commonly used in
agricultural products and
cross-referenced them to
more than 1,000 trade
names. This list was then
taken to agricultural dealers
in the county, who
identified which products
were being used by the
local farm community.
With information supplied
by the agricultural
distributors, LEPC
members calculated how
much of each product a
farmer would need to have
on hand to be subject to the
reporting requirements.
Posters with this
information were then
printed and distributed
throughout the county, as
were cards and mailing
labels that could be used by
farmers to report to the
LEPC and name a "facility"
coordinator to the LEPC.
Develop Booklets and
Brochures
To further spread the word,
many states have produced
booklets and brochures that
explain Title III. These
may be general in scope, or
may be targeted to specific
audiences such as small
businesses or farmers.
Kansas developed a
brochure titled Guide to
Community Right-to-Know
Compliance under SARA
and Kansas Laws, which
explains how to determine
whether a facility is
covered under the
regulations, and how to
comply if it is. Kansas also
developed a document
titled Summary of
Registered Pesticides and
Pharmaceutical Products in
Kansas, which lists EHSs
by their trade names and
gives threshold planning
quantities in gallons rather
than pounds, in order to be
more familiar to farmers.
The booklet even tells how
many flea collars add up to
the threshold planning
quantity.
The Alexandria, Virginia,
LEPC published a
comprehensive document,
What Alexandria
Businesses Should Know
About SARA Title HI. to
explain Title HI
requirements and the role
of the LEPC. The
document was distributed
to all businesses that had
been issued a hazardous
materials use permit. The
Alexandria Chamber of
Commerce also helped the
(continued on page 4)
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MAKING
WORK
Ignorance Is No Defense
(continued from page 3)
LEPC create an exhibit for
local business conventions.
Title III information has
been distributed at trade
shows, at the state fair, and
to community groups and
trade organizations
throughout the city.
Work With Your SERC
and EPA
LEPCs should also work
with their states and EPA to
identify and target Title ffl
facilities. States can help
by identifying facilities
from state permit lists,
providing outreach
materials, and providing
direct technical assistance.
Projects aimed at
improving Title in
compliance have been
conducted by LEPCs with
assistance from states and
EPA in Alabama,
Wyoming, North Dakota,
and Oklahoma.
In 1988 and 1989, the
Calhoun County,
Alabama, Emergency
Management Agejicy,
worked with two state
agencies—the Department
of Environmental
Management and the
Emergency Management
Agency—on a pilot
compliance project with the
assistance of EPA Region
4. The team used Dun &
Bradstrect data, EPA's list
of water and RCRA permit-
holders, Title IE toxic
release inventory reports,
county industry and
business listings, the
telephone directory, and
Getting Started: Resources
There are many different types of databases and other sources of information available
to SERCs and LEPCs that can help identify facilities potentially covered by Title III.
Some of the most promising include:
Dun & Bradstreet Database
Content: Contains information on more than 1.1 million U.S. business
establishments with 10 or more employees.
Online Service: STM Systems Corp, $125 initiation fee, system updated every 6
months.
For Further Information Contact: 800-223-1026
Toxic Release Inventory (TRD Database
Content: Contains information on the annual estimated releases of over 300
toxic chemicals into the environment. Includes 80,000+ records
containing data from about 21,000 manufacturing facilities that
employ more than 10 people and manufacture, process, or use
specified chemicals at or above certain threshold amounts.
Online Service: National Library of Medicine (NLM) (TRI) (as part of TOXNET),
updated annually, $18-$25 per hour. TRI is also available from state
agencies and on microfiche in many county libraries.
For Further Information Contact 301-496-6193
Other Sources
Lists of permittees under the Resource Conservation and Recovery Act (RCRA), the
Clean Air Act, and the Clean Water Act, which may be obtained by contacting your state
environmental agency; lists of local facilities that report releases to the National
Response Center; and lists of businesses with hazardous materials permits from the local
fire department.
local contacts and
interviews to add to the
county's existing list of
companies subject to Title
m.
After identifying 47
facilities likely to be
subject to regulation that
hadn't yet reported, the
LEPC mailed these
facilities a comprehensive
package of Title III
materials, including an
explanatory cover letter, a
Title HI Fact Sheet, the list
of extremely hazardous
substances, a flow chart on
reporting hazardous
materials spills, and a list of
Title HI filing addresses.
With the assistance of EPA
Region 4, teams of
government officials then
visited unresponsive
facilities suspected of being
covered by Title HI. These
visits produced the most
significant results of the
project: 12 businesses
subject to section 302 and
17 entities subject to
sections 311-312 were
identified and informed of
their reporting obligations.
Within several weeks,
almost all had filed the
appropriate reports.
Use the Media
Another effective way to
reach and educate industry
is through the media.
Many LEPCs have worked
with local newspapers and
radio stations to inform the
community, and especially
potentially covered
facilities, of Title El
requirements.
(continued on page 7)
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MAKING
WORK
LEPCs and SERCs
are by no means
powerless when a
company fails to comply
with right-to-know laws. A
variety of options are
available to "persuade" lax
facilities into compliance—
including federal
enforcement actions.
Under section 325 of the
Emergency Planning and
Community Right-to-Know
Act (commonly known as
EPCRA or Title HI), the
federal government is
authorized to bring
administrative and civil or
criminal judicial action
against violators. EPA can
assess civil and
administrative penalties
ranging from $10,000 per
violation to $75,000 per
violation per day of
violation on the owner or
operator of a facility that
fails to comply with
emergency planning
(section 302), emergency
notification (section 304),
community right-to-know
(sections 311-312), toxic
chemical release (section
313), and trade secret
reporting (sections 322-
323) requirements.
Criminal penalties of up to
$50,000 or five years in
prison may also be levied
on any person who
knowingly and willfully
fails to provide emergency
release notification. To
date, there have been more
than 400 Title III
complaints filed. Total
proposed penalties have
reached nearly $11 million,
and so far, $1.5 million has
been collected.
ENFORCING TITLE HI:
WHEN VOLUNTARY
COMPLIANCE FAILS
State and Local
Actions
Enforcement at the federal
level is only one method of
getting a facility to comply
with the law. Section
326(a)(2) of Title III
authorizes state and local
suits as well. State and
local governments have the
authority to bring civil
actions in the U.S. District
court for failure to notify
under section 302; failure
to provide information
under section 303; failure
to submit MSDSs or a list
of MSDSs as required
under section 311; and
failure to submit facility-
specific information
required under section 312.
These actions do not
require prior
notification.
Title IH -•---
even
authorizes
citizens to initiate civil
actions against EPA,
SERCs, and/or the owner or
operator of a facility for
failure to meet legal
requirements. Under
section 326(a)(l), any
person has the authority to
file a civil action in the
U.S. District court for
failure to submit the
required MSDSs or Tier I
or Tier II information.
Suits and Settlements
Although EPA may go to
court to enforce
compliance, direct contact
with a facility owner or
operator may be the most
effective way for LEPCs
and SERCs to persuade the
facility to comply. But
outreach and dialogue may
not always be enough. If
an LEPC has attempted to
work cooperatively and a
facility still fails to respond
to the information request,
there is still another course
of action: the LEPC can
notify the facility owner or
operator that it intends to
file a civil action in the
U.S. District Court, or it
can assist the
SERC and
EPA in their
enforcement
efforts.
In these cases, thorough
documentation of activities
is essential. Establishing a
record of an LEPC's efforts
to encourage voluntary
compliance will aid the
state and EPA in taking an
enforcement action. Make
sure to maintain records of
telephone and other
contacts with facilities,
letters—anything that
seems relevant.
Even if the state or EPA
take formal legal action, a
cooperative settlement
usually follows.
Settlements have proven
effective means of
resolving Title HI
compliance problems. And
in some cases, innovative
settlements have provided
badly needed funding for
SERCs and LEPCs.
For example, EPA Region
1 filed a consent order in
November 1990 for a
settlement that will benefit
local emergency planners.
Champion International, a
large woodmill in Hancock
County, Maine, delayed
notifying the National
Response Center, SERC,
and LEPC after an
accidental release of
chlorine, thus violating
both CERCLA section 103
and Title III section 304.
The facility admitted its
negligence and arranged a
mutually beneficial
settlement with the
community.
Ultimately, Region 1
proposed a civil penalty of
$20,000 in its
administrative complaint,
however, the parties settled
for a penalty of $ 12,000,
$6,000 of which was paid
to the U.S. Treasury and
$6,000 was paid to the
"Hazardous Substance
Trust Fund." In addition,
the company provided
computer hardware.and
software to the Hancock
County LEPC of an
approximate value of
(continued on page 6)
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Enforcing Title in
(continued from page 5)
/
$5,000, which allowed the
county to expand its data
gathering capabilities.
Other innovative
settlements have called for
an external firm to conduct
an annual environmental
audit on the facility for a
specified period; for a
representative of the facility
to attend regularly
scheduled meetings of the
LEPC; and for the facility
to submit articles on Title
in reporting requirements
to industry journals.
State and Local
Legislation
books, and seven had plans
to introduce legislation
soon.
States and communities
have the option of passing
their own legislation to
augment enforcement
capabilities. As of early
1991,27 states already had
Title IH legislation on the
Section 302—Planning Notification Requirement. Requires the owner or operator
of a facility at which an extremely hazardous substance-(EHS) is present at or above a
threshold amount to notify the SERC and LEPC that the facility is subject to the
emergency planning provisions of Title HI.
Section 303 — Emergency Response Plans. To assist LEPCs in developing local
emergency response plans, this section requires the owner or operator of a facility subject
to section 302 to designate a facility representative who will participate in the planning
process. This section also provides authority for the LEPC to request any information
from a facility that it needs for emergency planning and response.
Section 304—Release Notification Requirement. Requires facilities to notify LEPCs
and SERCs immediately if there is a release into the environment of an EHS or hazardous
substance(at or aboveadesignatedreportablequantity)regulated under the Comprehensive
Environmental Response, Compensation, and Liability Act.
Section 311 — Reporting Requirements. Requires facilities that have hazardous
chemicals present above certain thresholds to submit either Material Safety Data Sheets
(MSDSs) or a list of MSDS chemicals to the LEPC, the SERC, and the local fire
department. MSDSs typically include the identity of chemicals and their hazardous
components, physical and chemical characteristics, fire and explosion hazard data,
reactivity and health hazard data, and precautions for safe use and control measures.
Section 312—Reporting Requirements. Requires facilities subject to section 311 to
submit an annual inventory form on the quantities and locations of hazardous chemicals
to the LEPC, SERC, and the local fire department. The facility may submit either a Tier
I, Tier n, or equivalentformdevelopedby the state. Tierlrequests aggregate information
on hazardous chemicals according to the type of physical and health hazards they
represent. The Tier II form requests chemical-specific information.
Section 313—Toxic Chemical Release Reporting. Requires manufacturing facilities
to complete a Toxic Chemical Release Inventory Form (Form R) estimating annual
releases to the environment (air, water, or land) for more than 300 specified toxic
chemicals, if they manufacture, process, or otherwise use certain chemicals above
specified thresholds during a calendar year. This information is reported to EPA and the
state, and is made available to the public through a national database.
A Wisconsin statute
authorizes the SERC to
initiate enforcement actions
against facilities for failure
to provide notification
pursuant to section 302(c),
failure to respond to a
request for information
pursuant to section 303(d),
or failure to submit a.
response to a request for
Tier II information pursuant
to section 312(e).
Illinois has passed the
"Illinois Emergency
Planning and Community
Right to Know Act," which
codifies Title III into state
law. In addition, the
Illinois Emergency
Services and Disaster
Agency became the first
state agency to make
referrals to EPA concerning
violations of section 304 of
Tide m.
In Washtenaw County,
Michigan, the County
Commissioners' passage of
right-to-know legislation
enables the county Board of
Health to require the
reporting of right-to-know
information, to inspect
facilities, to assess
penalties, and to assess
inspection fees. The law is
broader than Title HI in that
it covers chemicals on a
state registry as well as the
OSHA hazardous
chemicals.
The New York City LEPC,
which has one of the largest
and most complex planning
(continued on page 7)
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MAKING
WORK
Enforcing Title HI
(continued from page 6)
missions in the country, is
authorized by a local
regulation to conduct
inspections, initiate civil
actions, and assess
penalties for violations of
its own community right-
to-know law.
Setting Examples
Some LEPCs have used
enforcement measures
against individual offenders
as a means to improve
voluntary compliance
among other facilities. In
these cases, the LEPC
might enforce Title IE
requirements at a particular
facility within the
community and then
publicize the results widely.
This can be a simple, cost-
effective way of getting fast
results, since no facility
wants negative publicity in
local newspapers, radio, or
on TV news shows. Other
facilities will be likely to
respond if they are faced
with a fine or another
tangible example of what
might happen if they fail to
comply.
A large-scale enforcement
initiative is another
effective way to use
publicity to increase
compliance. In a national
initiative, cases throughout
all 10 EPA Regions are
filed simultaneously and
then publicized both in the
Regions and at
Headquarters. Between
1988 and 1990, EPA has
conducted three such coast-
to-coast enforcement
initiatives to highlight the
requirements of Title IE
and encourage full
compliance by other
facilities. These "sweeps"
heighten community
awareness and cause many
facilities to realize the need
to comply or risk uninvited
public scrutiny. •
Ignorance Is No Defense
(continued from page 4)
In Butler County, Kansas,
the LEPC persuaded the
local newspaper to run
articles on Title III and its
significance to the public.
The paper ran one major
article and several follow-
up pieces. The LEPC also
ran spots on the radio; one
LEPC member was a radio
disc jockey, and was able
to present the spots
himself.
Use Your Local Fire
Department
The fire department can be
another valuable ally in
reaching out to your
community. Under Tide
HI, LEPCs must include
local fire officials, who
typically lead the response
to hazardous material
accidents. Also, Title El
provides fire departments
with access to inspect
reporting facilities' storage
and handling of hazardous
chemicals. Fire
departments also work
closely with businesses on
fire prevention plans and
pre-fire plans. Fire fighters
are often familiar with a
facility's operations and are
in close contact with its
management, especially if
the facility has on-site
hazardous or flammable
materials. In some
communities, during
routine fire inspections or
other inspections, fire
departments have the
responsibility for assessing
whether a facility is subject
to Title IE.
An Alexandria, Virginia,
city ordinance requires all
businesses that store, use,
or handle hazardous
chemicals to obtain a
permit from the fire
department. As part of the
review and approval
process, the fire department
(continued on page 8)
EPA Regional Title ill Offices
EPA - Region 1
New England Regional Lab
60 Westview Street
Lexington, MA 02173
617-860-4300
EPA - Region 6
Allied Bank Tower
1445 Ross Avenue
Dallas, TX 75202-2733
214-655-2270
(CT,MA,ME,NH,RI,VT) (AR, LA, MM, OK, TX)
EPA - Region 2
Woodbridge Avenue
Edison, NJ 08837
908-321-6620
(NJ, NY, PR, VI)
EPA - Region 3
841 Chestnut Street
Philadelphia, PA 19107
215-597-1354
(DE, DC, MD, PA, VA,
WV)
EPA - Region 4
345 Courtland Street
Atlanta, GA 30365
404-347-1033
(AL, FL, GA, KY, MS,
NC,SC,TN)
EPA -Region 5
230 South Dearborn
Chicago, IL 60604
312-886-1964
(IL, IN, MI, MN, OH, WI)
EPA - Region 7
726 Minnesota Avenue
Kansas City, KS 66101
913-551-7005
(IA,KS,MO,NE)
EPA - Region 8
One Denver Place
999 18th Street, Suite 1300
Denver, CO 80202-1723
303-293-1723
(CO,MT,ND,SD,UT,
WY)
EPA-Region 9
75 Hawthorne Street
San Francisco, CA 94105
415-744-2100
(AS, AZ, CA, HI, NP, NV,
GU)
EPA - Region 10
1200 6th Avenue
Seattle, WA 98101
206-553-4349
(AK,ID,OR,WA)
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MAKING
WORK
Ignorance Is No Defense
(continued from page 7)
conducts a facility
inspection, which verifies
the types and quantities of
hazardous chemicals at the
site. When they file for a
use permit, the companies
aresent a comprehensive
Title III information
package. Failure to comply
with Title DI might prevent
the facility from receiving
its permit and, therefore,
from operating. Thanks to
this permitting process, the
city believes it has achieved
a high rate of compliance
with Title HI.
In addition to routine
permit inspections, the
Alexandria fire department
also conducts inspections to
identify facilities subject to
Title IE regulations that
haven't yet reported. The
fire department targets
businesses that haven't
reported but which are
believed, based on
department personnel's
knowledge and experience,
to handle hazardous
chemicals. •
Read More About It
The examples used in this bulletin are drawn
from EPA's series, Successful Practices in Title
III Implementation, which is available from
your regional Title HI office (see list on page 7),
or by calling the Emergency Planning and
Community Right-to-Know Information Hotline
at 800-535-0202. Seven bulletins are currently
available in this series, covering a wide variety
of Title HI implementation practices successfully
employed by a large number of SERCs and
LEPCs.
&EPA
United States
Environmental Protection Agency
(OS-120)
Washington, DC 20460
Official Business
Roo«Jty for Pfhrato Us«
$300
FIRST CLASS MAIL
Postage and Fees Paid
EPA
G-35
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