A violation of EPCRA for failing to timely file a Form R report carries a penalty of up to $32,500 per chemical per year for up to five years. USEPA created a program in which companies can voluntarily audit and self-disclose the violations. By self-auditing and self-disclosing any violations in a timely manner (following a prescribed format) a company can eliminate the penalty entirely. JET has been successful in completing the self-auditing and self-disclosure process for dozens of facilities -- all of which resulted in a 100% reduction of agency penalties. The audit involves a detailed review of files, records, and documents at the facility. The report will contain threshold planning quantity calculations of each substance listed pursuant to EPCRA in 40 CFR part 372, as well as a determination for each listed substance whether: (1) a Form R or Form A report was filed for the chemical for the applicable reporting years, (2) the Form R or Form A filed was erroneously filed, and (3) whether the Form R and Form A reports that were actually filed are accurate and correct based on chemical usage information.
JET will prepare the necessary Form R reports for the five year period , and will correct (or redact if appropriate) previously filed Form R reports. During preparation of the Form R reports, JET will develop emission estimation methods to be used at the facility. JET will also coordinate the submission of the necessary Form R reports to USEPA and state agencies.