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 THE 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 ACID FOR CALENDAR YEAR 1999 AND HAD COMMITTED DATA QUALITY REPORTING ERRORS 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 OF THE CONDITIONS OF EPA'S SELF- DISCLOSURE POLICY AND THE AMOUNT OF ECONOMIC BENEFIT GAINED WAS INSIGNIFICANT, EPA WAIVED THE GRAVITY-BASED CIVIL PENALTY FOR THE DISCLOSED VIOLATIONS.