A review of the Toxic Release Inventory Envirofacts Database (TRI Database) indicated that the Respondent voluntarily submitted the following Form A reports to the EPA:
DOCUMENT CONTROL NUMBER YEAR CHEMICAL NAME FORM TYPE DUE
DATE POSTMARK DATE DAYS LATE
1399131108577 1999 ETHYLENE GLYCOL A 07/01/00 10/14/02 >1yr
1399131108589 1999 ZINC COMPOUNDS A 07/01/00 10/14/02 >1yr
1399131108603 1999 HYDROGEN FLUORIDE A 07/01/00 10/14/02 >1yr
1300141118087 2000 ETHYLENE GLYCOL A 07/01/01 10/14/02 >1yr
130014118099 2000 ZINC COMPOUNDS A 07/01/01 10/14/02 >1yr
1300141118113 2000 HYDROGEN FLUORIDE A 07/01/01 10/14/02 >1yr
1301151099850 2001 ETHYLENE GLYCOL A 07/01/02 10/14/02 104
1301151099862 2001 ZINC COMPOUNDS A 07/01/02 10/14/02 104
1301151099886 2001 HYDROGEN FLUORIDE A 07/01/02 10/14/02 104
On July 2, 2003, a letter addressing the above late reporting violations was sent to the company in an effort to gain more insight into the circumstances concerning the above violations. On July 21, 2003, The S.A. Day Mfg. Co., Inc. provided the requested information. Based on this information, it was determined that the company was required to submit the Form R or Form A reports for calendar years 1999, 2000, and 2001 to the Administrator of EPA and to the State of New York. The failure to submit the Form R or Form A reports, in a timely manner, constitutes
a violation of Section 313 of EPCRA, 42 U.S.C. � 11023, and 40 C.F.R. � 372.30. The amount of the penalty was i