3/22/2013 - NOD ISSUED. THE FACILITY VIOLATED EPCRA SECTION 312; HOWEVER HORTON'S SELF DISCLOSURE MET THE CONDITIONS OF THE EPA AUDIT POLICY FOR 100% ELIMINATION OF THE GRAVITY-BASED OF THE PENALTY FOR THE VIOLATION. EPA WILL NOT SEEK GRAVITY-BASED PENALTIES FOR THE VIOLATION. IN ADDITION, FOR PURPOSES OF THIS DISCLOSURE, EPA WILL NOT SEEK ANY ECONOMIC BENEFIT PENALTY ASSOCIATED WITH THE VIOLATION. EPA EXPECTS HORTON TO INSTITUTE ON A CONTINUING AND CO. WIDE BASIS POLICIES AND PROCEDURES NECESSARY TO PREVDENT RECURRENCE OF VIOLATIONS.