COUNT 1
Failure to submit in a timely manner a Form R for manufacturing approximately 47,912 pounds of copper compounds for calendar year 2001.
Proposed Penalty = $5,500.
COUNT 2
Failure to submit in a timely manner a Form R for manufacturing approximately 53,124 pounds of copper compounds for calendar year 2002.
Form R reports less than one year late. The due date for 2002 was July 1, 2003. The Form R postmark date was May 25, 2004. The Form R was 330 days late.
Proposed Penalty = $5,066
COUNT 3
Failure to submit in a timely manner a Form R for manufacturing approximately 663 pounds of lead compounds for calendar year 2001.
Form R reports greater than one year late. The due date for 2001 was July 1, 2002. The Form R postmark date was April 27, 2004. The Form R was greater than one year late.
*Proposed Penalty = $0.
*As 2001 was the first year that facilities were required to submit Form R reports for lead and/or lead compounds under the PBT Rule, EPA is mitigating penalties for not filing a timely Form R for lead to $0 for the 2001 reporting year in conformance with HQ guidance. If a penalty was assessed for this violation, it would have been $5,500.