U.S. EPA filed an Administrative Complaint against a wood furniture manufacturer client seeking $136\,000 in civil penalties for EPCRA Form Rs late filing after a U.S. EPA inspection. Varnum's defense investigation revealed one chemical had been overstated and the actual quantity was less than the reporting threshold. A corrected filing was made and that claim was dismissed. The client also proposed a Supplemental Environmental Project (SEP) to reduce solvent air emissions, and the final penalty was reduced by 85% with payments over 3 years.