A self-disclosure regarding violations at the facility was submitted to the U.S. EPA under the Audit Policy. The disclosure indicated that Toxic Release Inventory (TRI) Form R reports as required by Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) for copper and lead for years 2000 to 2009 had not been submitted in a timely manner. The Respondent has submitted all required TRI Form R reports.