COUNT 1
Failure to submit in a timely manner a Form R for processing approximately 888 pounds of lead for calendar year 2001.
Proposed Penalty = $5,500
*Actual Penalty Proposed in Complaint = $0
COUNT 2
Failure to submit in a timely manner a Form R for processing approximately 1678 pounds of lead for calendar year 2002. (10X threshold)
Proposed Penalty = $18,700.
COUNT 3
Failure to submit in a timely manner a Form R for processing approximately 870 pounds of lead for calendar year 2003.
Proposed Penalty = $5,500
Total Proposed Penalty Before any Reductions = $29,700
Adjusted Penalty Proposed in Administrative Complaint = $24,200
*(Hq has requested that penalties for the PBT chemical lead be assessed at $0 for calendar 2001 as it was the first year that facilities were required to file Form R reports under the new lowered threshold of 100 pounds.)
Due to inability to pay issues verfied indicated by and ABLE analysis, a settlement offer of $1,500 was accepted.