On October 13, 2005, Bumper disclosed to EPA within 21 days of discovering that it had failed to submit Toxic Chemical Release Inventory Reporting Form R or A reports for diisocyanates for reporting years 2000 thru 2004. The failure to submit in timely manner complete and correct Form R or A reports for diisocyanates, a listed toxic chemical category, constitute failures to comply with Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), 42 U.S.C. � 11023, and with 40 C.F.R. � 372.30.