On October 13, 2010 the Respondent, located in Wyckoff, NJ disclosed under the Audit Policy that it had failed to submit Toxic Chemical Release Inventory Reporting Form R reports for zinc (fume or dust) for 2005, 2006, 2007, 2008 and 2009. Failures to submit complete and correct Forms R or A reports for the listed toxic chemical in a timely manner constitute failures to comply with Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). Pursuant to the Audit Policy and based on information provided, EPA has determined that the facility meets the conditions of the Audit Policy for 100% elimination of the total gravity-based penalties. Respondent corrected all violations that were disclosed in October 13, 2010 Audit Policy request.