On September 8, 2003, EPA entered into a SuperCAFO with Bird-in-Hand Woodworks, Inc. resolving two EPCRA 313 1999 TRI reporting violations. The parties agreed to settle the violations for $500. The reason for the modest penalty was because the company had no prior history of environmental violations, the filing omission was due to a mathematical mistake by Respondent���s environmental consultant after it had reviewed the company���s processing information for 1999, and because Respondent spent $2.6 million in the late 1990s on a process change that all but eliminated the use of VOCs at its facility. In 1997 the company had generated 37 tons of VOCs whereas in 2001 it had reduced these amounts to 4 tons while dramatically increasing production. Had it not instituted the process change, the company would have generated 125 tons of VOCs. As a result of this process change, Bird-in-Hand is under consideration for the Pennsylvania���s Governor���s Award for Environmental Excellence. Under the circumstances, the Region decided that assessing a significant penalty against Respondent would send the wrong environmental messag