LATE REPORTER INITIATIVE - This is a consolidated action pursuant to our Consolidated Rules of Practice, 40 C.F.R. �22.18(b)(2) and (3), which provide that a proceeding may be simultaneously commenced and concluded by the issuance of a Consent Agreement and Final Order when the parties agree to settle one or more causes of action before the filing of an Administrative Complaint.
A review of the Toxic Release Inventory Envirofacts Database (TRI Database) indicated that Rochester Plating Works, Inc. voluntarily submitted to the EPA late Form R reports for the following:
Chemical Name Reporting Year Report Due Report Submitted Days Late
zinc compounds 1997 July 1, 1998 September 28, 2000 >365
zinc compounds 1998 July 1, 1999 September 28, 2000 >365
nitrate compounds 1999 July 1, 2000 March 18, 2003 >365
nickel compounds 1999 July 1, 2000 March 18, 2003 >365
zinc compounds 1999 July 1, 2000 September 28, 2000 88
zinc compounds 2000 July 1, 2001 March 18, 2003 >365
nickel compounds 2000 July 1, 2001 March 18, 2003 >365
zinc compounds 2001 July 1, 2002 March 18, 2003 259
On January 10, 2003, a letter was sent to the company to address these late reporting violations and to request additional information. Based on the information provided by Rochester Plating Works, Inc�s initial response and subsequent communications the late reporting was confirmed.
These failures to submit the Form R reports, in a timely manner, constitute violations of Section 3