'CAFO issued 8/6/2002, assessing a penalty of $115,000. Respondent shall make two installment payments, the first payment of $57,500 is due within thirty days. The last payment is due by 8/6/2003. Respondent did not submit Notices of Commencement (NOCs) to the EPA for two chemical substances within thirty (30) days after their first commercial import. Respondent did not submit an Inventory Update Report (IUR) for fourteen chemical substances for the 1998 reporting year during the 1998 reporting period. Respondent did notify the processor or industrial user of the use restrictions or controls of a chemical substance subject to the requirements of this section on twenty-five separate occasions