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UNITED STATES ENVIRONMENTAL PROTECTION AGEYGY
--
BEFORE
THE
ADMINISTEATOR
I.
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-
1
/--
\
-7-
7
IN THE MATTER OF
1
o
)
.
-.
1
LJ
07
ALL REGIONS CHEMICAL LABS,
)
Docket No. CERCLA-1-88-1089
INC.,
1
Respondent
1
INTERLOCUTORY ORDER GRANTIPG COMPLAINANT'SMOTION FOR PARTIAL ACCELERATED DECISIONCornplainant has filed a motion, pursuant to Section 22.20(a)of the Consolidated Rules of Practice,
40
C.F.R.
Part
22,
for apartial accelerated decision in favor of the Complainant as toliabi1
i
y in this proceeding without further hearing, contendingthat no genuine issue of material fact exists and the Conpiainantis entitled to judgment as a matter of law as to both counts
rrf
thecomplaint.In support of this motion, the Complainant contends:
1.
Respondent admitted a11 material facts that constitute theviolation of notification requirements of Section 103
of
theComprehensive Environmental Response, Compensation, and LiabilityAct (CERCLA),
42
U.S.C.
§
9603,
as
set forth in Count
I
f the com-plaint.
2.
Respondent admitted all material facts that constitute theviolation of the written followup notice requirement of Section
304
of the Emergency Planning and Community
Ri
ght-To-Know Act (EPCRTKA),
 
[a. k.a. Title 111 of the Superfund Amendments and ReauthorizationAct of 1986 (SARA)], 42
U.S.C.
§
11004, as set forth in Count
I1
of the complaint.Respondent has filed a memorandum in opposition, maintainingthat such an accelerated decision would not in any way expedite thedisposition of the case and would run contrary to the provisions ofboth statutes with respect to criteria to be taken into considera-tion in determining the amount of any penalty.l/Upon consideration of the pleadings, the prehearing exchangesfiled by the parties, the motion and supporting memorandum filed bythe Complainant and the memorandum filed by the Respondent,
I
con-clude that the motion should be granted.
I.
The ComplaintAn administrative complaint was issued on September 30, 1988,under Section 103 of CERCLA, 42
U.S.C.
5
9609, and Section 325(b)of Title
I11
of
SARA,
or EPCRTKA, 42
U.S.C.
§
11045(b).
11
In support of their respective positions, both parties havereliea, in part, upon the Federal Rules of Civil Procedure. Whilethe Federal Rules of Civil Procedure may provide useful guidance,
it
should be noted that they do not govern the procedure in administra-tive agencies which enjoy "wide latitude" to fashion their ownrules of procedure. In the Matter of Katzson Brothers, Inc., FIFRAAppeal No. 85-2 (~inaiakreeFarm Dairy, Inc. v. Block, 544 F. Supp. 1351, 1356, n. 3 (-E.D.N.Y.1982). See also, South Central Bell Tel. Co. v. Louisiana PublicServ. Comm'n, 570 F. Supp. 227, 232 (D.C. La. 19831, aff'd 744 F.2d1107 (5th
Cir.
1984) and Federal Communications Cornm. v. PottsvilleBroadcasting Co., 309
U.S.
134, 143 (1940).
 
The complaint a1 eged that Respondent had violated Section 103(a)of CERCLA, 42 U.S.C.
§
9603(a), and Section 304 of EPCRTKA orTitle
111
of SARA, 42 U.S.C.
§
11003. Section 103(a) requires aperson in charge of a vessel or an offshore or onshore facility,as soon as he or she has knowledge of a release of a hazardoussubstance from such vessel or facility in an amount equal orgreater than the reportable quantity (RQ) of that substance, tonotify immediately the National Response Center.2/ Section304(c)3/ requires an owner or operator of a facility, as soon aspracticable after a release that requires notice under Section21 Section 103(a), 42
U.S.C.
§
9603(a), provides, in perti-nent part:"Any person in charge of.. .an onshore facility shall, assoon as he has knowledge of any release.. .of a hazardous substancefrom such.. .facility in quantities equal to or greater than thosedetermined pursuant to section 9602 of this title, immediatelynotify the National Response Center.
.
of such release.
"
31
Section 304(c), 42 U.S.C.
§
11003(c), provides:
-
"As soon as practicable after a release which requires no-tice under subsection (a) of this section, such owner or operatorshall provide a written followup emergency notice (or notices, asmore information becomes available) setting forth and updating theinformation required under subsection (b) of this section, and in-cluding additional information with respect to--(1) actions takento respond to and contain the release,(2) any known oranticipated acute or chronic healthrisks associated with the release, and(3) where appropriate, advice regarding medical attentionnecessary for exposed individuals."
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