On July 8, 2002, Noveon, Inc. submitted a written and signed statement of voluntary disclosure to EPA, stating that they had failed to file EPCRA Form R Toxic Release Inventory Reports for formaldehyde for calendar years 1997, 1998, 1999 and 2000. Prior to February 28, 2001, the facility was owned by the Specialty Chemicals Division of BF Goodrich Company. Noveon, Inc. voluntarily submitted the Form R reports as a result of a company audit conducted to review reporting requirements as the current owner. The failure to report these Form R reports in previous years by the previous owner was discovered on June 21, 2002. EPA records indicate that the missing Form R reports were sent to the U.S. EPA on July 11, 2002 within the 60 day period allowed under the Audit Policy.