CAFO issued 8/3/2004, assessing a penalty of $33,269. Respondent shall make the first payment due by 12/2004. The last payment due by 11/2005. Respondent failed to submit Form Rs or Form As for reporting year 2001 and 2002 for chromium, manganese, and nickel to the Administrator of EPA in a timely manner by July 1, 2001 and July 1, 2002. Respondent failed to submit a completed emergency and hazardous chemical inventory form for iron, manganese, graphite, and chromium at its facility for calendar years 2000 and 2001 to the LEPC, the SERC, and the appropriate fire department by March 1, 2001 and March 1, 2002