CAFO issued 1/28/2003, assessing a penalty of $5,000. Respondent failed to submit the 1998 IUR to the EPA during the reporting period (August 25, 1998 through January 31, 1999) for Chemicals A through S. Respondent failed to submit a written notice to the EPA on the dates Chemicals T, U and V were exported or within seven days of the intent to export Chemicals T, U and V.