This is a consolidated action pursuant to our Consolidated Rules of Practice (40 C.F.R. �22.18(b)(2) and (3)), which provide that a proceeding may be simultaneously commenced and concluded by the issuance of a Consent Agreement and Final Order when the parties agree to settle one or more causes of action before the filing of an Administrative Complaint.
A review of the Toxic Release Inventory Envirofacts Database (TRI Database) indicated that the Respondent voluntarily submitted the following Form R reports to the EPA:
CHEMICAL YEAR DUE DATE POSTMARK DATE DAYS LATE
STYRENE 2000 7/01/01 10/08/02 >1yr
STYRENE 2001 7/01/02 10/08/02 100
A review of the Toxic Release Inventory Envirofacts Database (TRI Database) indicated that the Respondent voluntarily submitted late Form R reports for styrene for calendar years 2000 and 2001. On July 1, 2003, a letter addressing the above late reporting violations was sent to the company in an effort to gain more insight into the circumstances concerning the above violations. By letter dated July 31, 2003, Mr. Benny Axelson, Human Resources Manager, Hobby World Development Inc. provided the requested information. Based on this information, it was determined that during years 2000 and 2001 the company had otherwise used (as defined in 40 C.F.R. � 372.3) greater 10,000 pounds of styrene each year. Each failure to submit the Form R, in a timely manner, constitutes a violation of Section 313 of EPCRA, 42 U.S.C. �11023, and 40 C.