COUNT 1
Failure to submit in a timely manner a Form R or Form A for processing greater than 25,000 pounds of phthalic anhydride for calendar year 2000.
EVIDENCE: Documents from the initial January 24,2002 inspection and the follow-up November 19, 2003 inspection. The company filed a Form A for this chemical on December 23,2003.
Proposed Penalty = $5,500
COUNT 2
Failure to submit in a timely manner a Form R or Form A for processing greater than 25,000 pounds of phthalic anhydride for calendar year 2001.
EVIDENCE: Documents from the initial January 24,2002 inspection and the follow-up November 19, 2003 inspection. The company filed a Form A for this chemical on December 23,2003.
Proposed Penalty = $5,500
COUNT 3
Failure to submit in a timely manner a Form R or Form A for processing greater than 25,000 of phthalic anhydride for calendar year 2002.
EVIDENCE: Documents from the initial January 24, 2002 inspection and the follow-up November 19, 2003 inspection. The company filed a Form A for this chemical on December 23, 2003. The Form A was 175 days late.
Proposed Penalty = $3,198
Total Proposed penalty on all counts: $14,198