The company failed to submit to the USEPA Administrator and to the State of New York complete and correct EPCRA Toxic Release Inventory Form R reports for the dichloromethane it used at its facility for calendar years 1997, 1999 and 2000. These failures to submit the Form R reports in a timely manner constitute violations of Section 313 of EPCRA, 42 U.S.C. �11023, and 40 C.F.R �372.30. The amount of the penalty was initially calculated using the Enforcement Response Policy (ERP) for Section 313 of EPCRA issued by the USEPA Office of Compliance Monitoring, Office of Pesticides and Toxic Substances, on August 10, 1992. Originally, a penalty of $48,939 was proposed in the Complaint.