MW Industries Inc. Â Atlantic Spring Division (MW Industries Inc.) submitted a Form R on December 12, 2008 which was 164 days late. The amount of the penalty was 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 April 12, 2001. The original proposed penalty would have been $14,072 if an administrative complaint had been issued.