IN THE YEAR 2009, THE FACILITY PROCESSED COPPER IN EXCESS OF $25,000 POUNDS, AND FILED THE REQUIRED TOXIC INVENTORY RELEASE FORM ON TIME. THE FORM INCORRECTLY REPORTED 582 POUNDS OF COPPER HAD BEEN TRANSFERRED OFF SITE, WHERE AS THE ACTUAL AMOUNT OF COPPER TRANSFERRED OFF SITE WAS 11,164 POUNDS. RESPONSENT DISCLOSED THE ERROR TO EPA ON APRIL 15, 2011.