1/23/12 - NOTICE OF DETERMINATION ISSUED. ON JULY 1, 2009, TORPEDO SUBMITTED ITS SELF-DISCLOSURE TO EPA IN WHICH IT DISCLOSED THAT IT HAD POTENTIALLY VIOLATED EPCRA 313 BY FAILING TO SUBMIT TRI FORM Rs FOR LEAD COMPOUNDS, COPPER, AND NICKEL COMPOUNDS FOR REPORTING YEAR 2007 FOR ITS ROCKY MOUNT PLANT. AFTER REVIEW OF TORPEDO'S SELF-DISCLOSURE, EPA HAS CONCLUDED THAT TORPEDO DID VIOLATE EPCRA 313 AS SET FORTH IN THE SELF-DISCLOSURE BY FAILING TO SUBMIT THE REQUIRED FORM Rs FOR REPORTING YEAR 2007 TO EPA BY THE FILING DEADLINE OF JULY 1, 2008. EPA NOTES THAT TORPEDO'S SELF-DISCLOSURE WAS SUBMITTED PURSUANT TO EPA'S AUDIT POLICY. HOWEVER, BECAUSE THE COMPANY HAS FEWER THAN 100 EMPLOYEES, EPA CONSIDERS TORPEDO TO BE A SMALL BUSINESS. AS SUCH, TORPEDO'S SELF-DISCLOSURE HAS BEEN ANALYZED IN ACCORDANCE WITH EPA'S SB POLICY RATHER THAN THE AUDIT POLICY. THE SB POLICY HAS SIMILAR BUT SOMEWHAT DIFFERENT CRITERIA THAN THE AUDIT POLICY.