EPA v. Combe Products, Inc.

Case summary

On July 20, 2005 Combe Products, Inc. disclosed possible violations to the U.S. Environmental Protection Agency (EPA) pursuant to EPA�s Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations, 65 FR 19618, April 11, 2000, effective May 11, 2000 (Audit Policy). In the disclosure, Combe Products, Inc. , located in Naguabo, Puerto Rico, indicated that it had failed to file Form R reports, in a timely manner, for lead compounds for Reporting Years 2002 and 2003 in violation of 40 CFR Part 372. A gravity-based penalty total of $60,000, could have been assessed for these non-reporting violations. The facility meets the conditions of the Audit Policy for 100% elimination of gravity-based penalties for these violations and an NOD had been prepared. Complying Action Calculation: [1 Form Rs (1st reporting year) * $ 4,796 Reporting per Form R] + [1 Form Rs (subsequent reporting year) * $ 3,274 Reporting per Form R] + [2 Form Rs * $283 Record Keeping per Form R] = $8,636

Defendants (1)

• Combe Products, Inc.Named in settlement

Facilities (1)

• COMBE PRODUCTS

  EL DUQUE INDUSTRIAL PARK RD 971 ST A, NAGUABO, PR, 00718

  Registry ID: 110022522019

Statutes cited

• EPCRA 313 — Toxic Chemical Release Reporting (TRI)

Enforcement conclusions (1)

• Combe Products, Inc.entered 2005-10-27

  Primary law: EPCRA

Timeline (3 milestones)

• 2005-10-27Final Order Issued
• 2005-10-27Enforcement Action Closed
• 2005-11-23Enforcement Action Data Entered