COMPLAINT FILED 9/1/98 PROPOSING A PENALTY OF $22,044 COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO TIMELY SUBMIT A FORM R FOR MANGANESE FOR CALENDAR YEAR 1996. IN VIOLATION EPCRA SECTION 313. COUNT II RESPONDENT FAILED TO TIMELY SUBMIT A FORM R FOR N-METHYL-2-PYRROLIDONE FOR CALENDAR YEAR 1996. IN VIOLATION OF EPCRA SECTION 313. CACO ISSUED 9/1/98. RESPONDENT VOLUNTARILY DISCLOSED THE VIOLATIONS ALLEGED IN THE COMPLAINT IN ACCORDANCE WITH EPA'S POLICY - INCENTIVES FOR SELF-POLICING: DISCOVERY, DISCLOSURE, CORRECTION AND PREVENTION OF VIOLATIONS, 60 FR 66706 (DEC. 22, 1995), (AUDIT POLICY). EPA HAS DETERMINED THAT RESPONDENT HAS MET ALL THE CONDITIONS SET OUT IN THE AUDIT POLICY. THEREFORE, EPA IS MITIGATING THE FULL AMOUNT OF THE PENALTY PROPOSED TO BE ASSESSED IN THE COMPLAINT.