The corporation voluntarily disclosed that its Rochester, IN facility had not timely filed a Form R for Lead for reporting year 2002 with the US EPA or with the State of Indiana. At the time of making the disclosure to the US EPA, the facility submitted the delinquent Form R. The gavity-based penalty for the violation would be $11,705. The facility received no economic benefit from the noncompliance. Although the facility has an ISO 14001 certification, all such programs lack an EPCRA 313 compliance component. Therefore, the company meets 8 of the 9 criteria in the Self Policing Policy. U.S. EPA agreed to forgive 100% of the gravity-based penalty and the facility agreed to develop, with U.S. EPA approval, and implement an EPCRA 313 compliance program. There are stipulated penalties if the company fails to develop an approvable compliance program