This is a consolidated action pursuant to our Consolidated Rules of Practice (40 C.F.R. 22.18(b)(2) and (3)), which provide that a proceeding may be simultaneously commenced and concluded by the issuance of a Consent Agreement and Final Order when the parties agree to settle one or more causes of action before the filing of an Administrative Complaint.
In response to the letter of inquiry sent in January 2006 as part of the New Jersey Right to Know Program Initiative, VictorÂs Three-D voluntarily disclosed the failure to file Form A reports for ammonia for calendar years 2000, 2001, 2002, 2003 and 2004 and requested relief for any associated penalties under EPAÂs December 22, 1995 ÂIncentives for Self-Policing, Discovery, Disclosure, Correction and Prevention of ViolationsÂ, commonly known as the Audit Policy. The New Jersey Initiative offered companies the option of disclosing to the EPA under this policy.
A subsequent review of the Toxic Release Inventory Envirofacts Database indicated that Respondent voluntarily submitted late Toxic Release Inventory Form A reports for otherwise using ammonia on the following respective dates: see hard copy can't copy.