On July 6, 2004, Homasote Company (Homasote), located at 932 Lower Ferry Road, West Trenton, New Jersey disclosed to EPA that it may have to failed to file Form R reports in a timely manner for 1,1-dichloro-1-fluorethane, diisocyantes, and copper compounds for calendar year 2002 pursuant to EPA?s Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations, 65 FR 19618, April 11, 2000, commonly referred to as the Audit Policy. On or about July 6, 2004, Homasote submitted late Form R reports for the above chemicals in violation of 40 C.F.R. ? 372.30. EPA determined that Homasote met conditions for 75% penalty reduction under the Audit Policy. The gravity based penalty for these violations was calculated to be $73,700. EPA and Homasote simultaneously commenced and concluded the matter with a Consent Agreemet and Final Order (CAFO). The CAFO included payment of an $11,055 penalty.