On November 22, 2011 the Respondent self disclosed possible violations at three of its facilities, located in Fulton, Beaver Falls and Croghan, NY to the U.S. Environmental Protection Agency (EPA), pursuant to EPAÂs Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations (the Audit Policy). Violations disclosed were under the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312 for failure to include lead, sulfuric acid and/or gasketing raw material in Tier 2 reports. Pursuant to the Audit Policy and based on information provided, we have determined that the facility meets the conditions of the Audit Policy for 100% elimination of the total gravity-based penalties. The Respondent has remedied all EPCRA 312 Tier 2 reporting issues.