ON MARCH 28, 2002, EPA ISSUED A NOTICE OF DETERMINATION ( NOD ) PURSUANT TO THE FINAL POLICY STATEMENT ON INCENTIVES FOR SELF-POLICING: DISCOVERY, DISCLOSURE, CORRECTION, AND PREVENTION OF VIOLATIONS , 65 FED. REG. 19618 (APRIL 11, 2000). THE NOD IS BASED ON SELF- DISCLOSURES PROVIDED BY HANDY & HARMAN TUBE CO., INC. ( HANDY & HARMAN OR FACILITY ) FOR VIOLATIONS OF SECTION 313 OF EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT (EPCRA), 42 U.S.C. SECTION 11023 AND ITS IMPLEMENTING REGULATIONS AT 40 C.F.R. PART 372. THE FACILITY IS LOCATED AT 701 W. TOWNSHIP LINE ROAD IN NORRISTOWN, PA. IN LETTERS DATED JULY 31, 2000, SEPTEMBER 24, 2001, OCTOBER 5, 2001 TO EPA AND IN A SUBSEQUENT RESPONSE TO AN EPA QUESTIONNAIRE, HANDY & HARMAN DISCLOSED THAT THE FACILITY HAD FAILED TO SUBMIT TOXIC RELEASE INVENTORY FORMS ( FORMS RS ) FOR HYDROGEN FLUORIDE AND NITRIC ACIDE FOR CALENDAR YEAR 199 AND HAD COMMITTED DATA QUALITY REPORTING ERROR FOR TRICHLOROETHYLENE, NITRIC ACID, AND HYDROGEN FLUORIDE FOR YEARS 1997-1999. THE TOTAL GRAVITY-BASED CIVIL PENALTY FOR THESE VIOLATIONS WOULD BE $48,122. HOWEVER, BECAUSE HANDY & HARMAN SATISFIED ALL THE CONDITIONS OF EPA'S SELF- DISCLOSURE POLICY AND THE AMOUNT OF ECONOMIC BENEFIC GAINED WAS INSIGNIFICANT, EPA WAIVED THE GRAVITY-BASED CIVIL PENALTY FOR THE DISCLOSED VIOLATIONS.