THIS ADMINISTRATIVE PENALTY ORDER IS ISSUED TO ADVANCED SURFACE TECHNOLOGIES FOR FAILURE TO SUBMIT A COMPLETE AND ACCURATE FORM R OR FORM A FOR CALENDAR YEARS 1997 AND 1998 FOR NITRATE COMPOUNDS TO THE ADMINISTRATOR OF EPA AND TO THE STATE OF COLORADO WITHIN THE REQUIRED TIME FRAMES. THIS ORDER IS SUBJECT TO THE 22 RULE WHICH IS ENTERED INTO BY THE PARTIES FOR THE PURPOSE OF SIMULTANEOUSLY COMMENCING AND CONCLUDING THIS MATTER. THE ASSESSED PENALTY FOR THIS VIOLATION IS $1,000.