On December 24, 2003 Harvey Hubbell submitted a written and signed statement of voluntary disclosure for late filing of Form R reports for copper for 1998-2000 for two facilities - Aibonito and Vega Baja. EPA reviewed the disclosure and issued a final determination in the NOD. EPA determined in the NOD that Hubbell did not meet the conditions of the Audit Policy for 100% elimination of the total gravity-based penalties for these violation. A complaint/cafo will be issued at a later date.