This case is a self-disclosure under the Audit Policy. The disclosure is dated November 30, 2007. During the course of GEÂs internal compliance review, it was determined that MDS had been subject to filing TRI Form R reports for lead, but had never filed any TRI Form R reports. The Form R reports for lead for MDS for 2004, 2005 and 2006 were initially filed December 21, 2007. The disks submitted for 2005 and 2006 were corrupted and were therefore resubmitted February 5, 2008. Subsequently, GE MDS LLC submitted TRI Form R reports for lead, in a timely manner, for years 2007 and 2008. EPA mitigated the penalty by 100% under the Audit Policy.