Respondent failed, in a timely manner, to submit to the Administrator and to the State of New York a complete and correct Form R for copper for the 1998 calendar year.
Respondent failed, in a timely manner, to submit to the Administrator and to the State of New York a complete and correct Form R for copper for the 1999 calendar year.
Respondent failed, in a timely manner, to submit to the Administrator and to the State of New York a complete and correct Form R for copper for the 2000 calendar year.
Respondent's failure to submit in a timely manner complete and correct Form R or Form A reports for the above-described toxic chemicals constitutes a failure or refusal to comply with Section 313 of EPCRA (42 U.S.C. �11023), and with 40 C.F.R. �372.30.