Failure to submit in a timely manner a Form R report for processing than 25,000 pounds of tetrachloroethylene during calendar year 2003.
EXTENT LEVEL:
(1) Category II:
< Form R reports less than one year late. The due date for 2003 was July 1, 2004. The Form R postmark date was December 23, 2004. The Form R was 175 days late.
(2) Extent Level C:
Less than $10 million in total corporate entity sales and greater than 50 employees.
< Facility processes less than ten times the 25,000 pound threshold of the ?313 chemical.
(3) Circumstance Level 4 - Failure to file a timely Form R.
PER DAY FORMULA FOR FAILURE TO REPORT IN A TIMELY MANNER:
Level 4 Penalty +
(# of days late - 1) X (Level 1 - Level 4 Penalty))/365 = $1,100 + ((174)($5,500 - $1,100))/ 365 = $3,198
Original Proposed Penalty = $3,198