COUNT 1
Failure to submit in a timely manner a Form R or Form A report for processing approximately 188,749 pounds of copper for calendar year 1999.
Proposed Penalty = $5,500.
COUNT 2
Failure to submit in a timely manner a Form R or Form A report for processing approximately 188,749 pounds of copper for calendar year 2000.
Proposed Penalty = $5,500.
COUNT 3
Failure to submit in a timely manner a Form R or Form A report for processing approximately 188,749 pounds of copper for calendar year 2001.
Proposed Penalty = $2,378
COUNT 4
Failure to submit in a timely manner a Form R for processing greater than 25,000 pounds of copper for calendar year 2003.
Proposed Penalty = $5,500.
COUNT 5
Failure to submit in a timely manner a Form R report for processing approximately 177 pounds of lead for calendar year 2001.
Proposed Penalty = $2,378
*Actual Penalty Proposed in Complaint = $0
NOTE: per endnote below we are actually assessing $0 for this count.
COUNT 6
Failure to submit in a timely manner a Form R for processing greater than 100 pounds of lead for calendar year 2003.
Proposed Penalty = $5,500.
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Total Proposed Penalty Before any Reductions = $26,756
Adjusted Penalty Proposed in Administrative Complaint = $24,378
*(Hq has requested that penalties for the PBT chemical lead be assessed at $0 for calendar 2001 as it was the first year th