This is a consolidated action pursuant to our ÂConsolidated Rules of Practice (40 C.F.R. Part 22 July 1, 2000)) which provide in 40 C.F.R. §22.13(b) that when the parties agree to settle one or more causes of action before the filing of an Administrative Complaint, a proceeding may be simultaneously commenced and concluded by the issuance of a Consent Agreement and Final Order pursuant to 40 C.F.R. §§22.18(b)(2) and (3). Facility failed to file timely TRI Form R reports for dioxin and dioxin-like compounds, lead, manganese, mercury and zinc (fume or dust) for 2004.