RESPONDENT PROCESSED MORE THAN 25,000 POUNDS OF THE TOXIC CHEMICAL COPPER COMPOUNDS IN EACH OF CALENDAR YEARS 2011 AND 2012 AT THE FACILITY WITHOUT TIMELY FILING THE REQUIRED REPORITNG FORM A OR FORM R WITH EPA AND THE COMMONWEALTH OF PENNSYLVANIA AS REQUIRED BY EPCRA SECTION 313 AND THE ASSOCIATED IMPLEMENTING REGULATIONS OF 40 C.F.R. PART 372.