Attached please find a Consent Agreement and Final Order for your signature. 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 Forms R to the EPA:
CHEMICAL YEAR DUE DATE POSTMARK DATE DAYS LATE
manganese compounds 1999 July 1, 2000 March 20, 2001 262
zinc compounds 1999 July 1, 2000 March 20, 2001 262
nickel compounds 2000 July 1, 2001 July 18, 2003 > 1 year
manganese compounds 2000 July 1, 2001 July 18, 2003 > 1 year
zinc compounds 2000 July 1, 2001 July 18, 2003 > 1 year
manganese compounds 2001 July 1, 2002 July 3, 2003 > 1 year
zinc compounds 2001 July 1, 2002 July 3, 2003 > 1 year
nickel compounds 2001 July 1, 2002 July 3, 2003 > 1 year