EPA ISSUED A NOTICE OF DETERMINATIOUN ( 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 A SELF-DISCLOSURE POLICY BY CLOSURE SYSTEMS INTERNATIONAL AMERICAS, INC. ( CLOSURE SYSTEMS ) FOR VIOLATION OF SECTION 312 OF THE EMEREGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT. CLOSURE SYSTEMS' FACILITY ( FACILITY ) IS LOCATED AT 4519 NORMAN ROAD, SANDSTON, VA 23150. CLOSURE SYSTEMS DISCLOSED THAT THE FACILITY HAD FAILED TO SUBMIT TIER II REPORTS TO THE LEPC, SERC, AND THE LOCAL FIRE DEPARTMENT FOR HYDRAULIC OIL AND PLASTIC PELLETS STORED AT THE FACILITY DURING THE 2006 AND 2007 CALENDAR YEARS, IN VIOLATION OF EPCRA SECTION 312.