8/14/2009. NOD ISSUED IN A LETTER DATED APRIL 22, 2008, WH MANUFACTURING, INC., ADMITTED THE FOLLOWING VIOLATIONS OF EPCRA: WH MANUFACTURING, INC. FAILED TO SUBMIT A TRI FORM FOR ITS FACILITY IN HOPKINSVILLE, KY FOR MANGANESE, NICKEL, COPPER, CHROMIUM, XYLENE, COBALT, AND LEAD FOR REPORTING YEARS 2004, 2005, AND 2006, TO EPA AND THE STATE, AS REQUIRED BY SECTION 313 OF EPCRA. ON MAY 30, 2008, WH MANUFACTURING, INC. SUBMITTED THE FORMS TO THE APPROPRIATE AGENCIES. UNDER EPA'S ENFORCEMENT POLICY FOR EPCRA VIOLATIONS, A GRAVITY-BASED PENALTY OF $984,192 COULD HAVE BEEN ASSESSED FOR THESE NON-REPORTING VIOLATIONS.