ON MARCH 31, 2005, EPA ISSUED A NOTICE OF DETERMINATION ( NOD ) BASED ON SELF-DISCLOSURES PROVIDED BY VANTEC INC., FOR VIOLATIONS OF SECTION 313 OF EPCRA AT ITS ONLY FACILITY AT 5902 LEWIS ROAD, SANDSTON, VIRGINIA. VANTEC DISCLOSED THAT IT HAD FAILED TO TIMELY SUBMIT TO EPA AND THE COMMONWEALTH OF VIRGINIA A FORM R FOR LEAD FOR REPORTING YEARS 2001 AND 2002 AND THAT ITS FORM R'S FOR COPPER AND NITRIC ACID FOR REPORTING YEARS 2000-2002 CONTAINED DATA QUALITY ERRORS. THE TOTAL GRAVITY-BASED CIVIL PENALTY FOR THESE VIOLATIONS WOULD BE $18,700.00. HOWEVER, VANTEC SATISFIED ALL OF THE CONDITIONS OF EPA'S SMALL BUSINESS COMPLIANCE POLICY AND THEREFORE EPA WAIVED THE GRAVITY-BASED CIVIL PENALTY FOR THE DISCLOSED VIOLATIONS. IN ADDITION, THE AMOUNT OF ECONOMIC BENEFIT GAINED FROM THE DISCLOSED VIOLATIONS WAS INSIGNIFICANT.