The facility was inspected and was found to have failed to file a Form R under section 313 of EPCRA for reporting year 1998. This inspection was part of a multimedia inspection conducted at the facility. The facility filed a delinquent Form R for manganese for calendar year 1998 on November 16, 1999. US EPA issued its complaint December 20, 2002, three years after the facility had come into compliance. The penalty was calculated and mitigated in accordance with the Enforcement Response Policy for EPCRA 313.