This is a consolidated action pursuant to our Consolidated Rules of Practice (40 C.F.R. �22.18(b)(2) and (3)), which provide that a proceeding may be simultaneously commenced and concluded by the issuance of a Consent Agreement and Final Order when the parties agree to settle one or more causes of action before the filing of an Administrative Complaint.
A review of the Toxic Release Inventory Envirofacts Database indicated that Respondent submitted late Toxic Release Inventory Form R reports for otherwise using ethylbenzene and xylene for calender year 2003. The due date for the Form R reports was July 1, 2004. The Form R reports were postmarked April 15, 2005, 288 days late.