ON 9/25/90, REGION V ISSUED A COMPLAINT AGAINST RESPONDENT ALLEGING VIOLATIONS OF SECTION 313 OF EPCRA FOR FAILURE TO SUBMIT FORM R FOR COPPER, A LISTED TOXIC CHEMICAL, AT ONE OF RESPONDENT'S FACILITIES IN AKRON. RESPONDENT HAD FILED THE PROPER FORMS AT ANOTHER OF ITS FACILITIES NEARBY. THE COM- PLAINT PROPOSED A PENALTY OF $5000. - ON 3/8/91, REGION V FILED A CAFO TO SETTLE THE CASE. THE PENALTY PAYMENT WAS REDUCED TO $1000, WHICH INCLUDED AN EBE (ENVIRONMENTALLY BENEFICIAL EXPENDITURE) MITIGATION BASED ON THE FACT THAT RESPONDENT HAD RECENTLY SPENT $156,000 IN WASTEWATER TREATMENT FACILITY ENHANCEMENT PROJECTS WHICH ENABLED RESPONDENT TO REDUCE THE DISCHARGE OF POLLUTANTS, INCLUDING COPPER, SIGNIFICANTLY BELOW ITS NPDES PERMIT LIMITS.