WEBCO SUBMITTED AN ELECTRONIC DISCLOSURE TO EPA ON MARCH 3, 2010, WHEREIN WEBCO DISCLOSED VIOLATIONS OF EPCRA SECTION 313 FOR ITS FAILURE TO SUBMIT TRI FORMS R FOR MANGANESE PROCESSED AT THE OIL CITY FACILITY DURING THE 2006, 2007 AND 2008 REPORTING YEARS, AND PROCESSED AT THE RENO FACILITY DURING HTE 2006 AND 2007 REPORTING YEARS. WEBCO ALSO DISCLOSED THAT IT FAILED TO SUBMIT A TRI FORM R FOR NICKEL PROCESSED AT THE OIL CITY FACILITY DURING 2008 REPORTING YEAR. THE TOTAL COMBINED GRAVITY-BASED CIVIL PENALTIES FOR THE VIOLATIONS THAT OCCURRED AT BOTH FACILITIES, CALCULATED IN ACCORDANCE WITH EPA PENALTY POLICIES.