This is an Administrative Penalty Order issued to Allfast Fastening Systems, Inc. for violations of EPCRA Section 313 for failure to timely submit reporting forms for copper and nickel processed in reporting years 2002 and 2003; and for nitric acid otherwise used in reporting years 2002 and 2003. Respondent voluntarily disclosed the violations and met all nine criteria of EPA's Audit Policy. As a result, the proposed penalty of $121,900 was reduced to zero dollars ($0).