This is an Administrative Penalty action pursuant to EPCRA Section 313 involving a violation in which Silpak Inc. failed to file timely Toxic Release Inventory Reporting Forms for diisocyanates in 2003 and 2004. Respondent sought penalty relief under the Small Business Policy but failed to meet all criteria necessary to receive 100% penalty reduction when it did not report the omissions within the required 21 days from the discovery of the violation(s). Calculated penalties for violations amount to $12,900 but Respondent has agreed to pay $9,030 after reductions allowed by the EPCRA Enforcement Response Policy.