Audit Policy Disclosure dated September 11, 2008. 100% Penalty Mitigation. If a Civil Administrative Complaint had been issued in this case for the non-reporting of copper and lead compounds for the calendar years 2003 to 2007, it would have included a proposed gravity-based penalty of up to $280,000. This penalty was calculated pursuant to Enforcement Response Policy for Section 313 of EPCRA. The company processes greater than 10 times the threshold value of 25,000 pounds for copper and 100 pounds for lead compounds.