Respondent submitted a self-disclosure to the US EPA on November 15, 2010 requesting penalty relief under the Audit Policy. The company failed to file timely Toxic Release Inventory Form R reports for lead and manganese compounds from years 2005 through to 2009 as required by Section 313 of the Emergency Planning and Community Right-to-Know Act. Respondent submitted the required TRI Form R reports on December 12, 2010.