Respondent submitted a voluntary self-disclosure under the Audit Policy on April 26, 2011. The required reports were submitted to the EPA on May 3, 2011. The Respondent's failure to submit, in a timely manner, Form R reports for polycyclic aromatic compounds (PACS) and benzo(g,h,i)perylene for calendar years 2007, 2008 and 2009 constitutes a failure to comply with Section 313 of EPCRA (42 U.S.C. §11023) and with 40 C.F.R. Part 372.