ON JUNE 21, 2013, EPA ISSUED A NOTICE OF DETERMINATION (NOD) PURSUANT TO THE SMALL BUSINESS COMPLIANCE POLICY TO ELECTRO CHEMICAL ENGINEERING & MANUFACTURING CO. FOR A VIOLATION OF SECTION 313 OF EPCRA, AND ITS IMPLEMENTING REGULATIONS. THE ELECTRO CHEMICAL FACILITY IS LOCATED AT 750 BROAD STREET, EMMAUS, PA 18049-0509. IN A LETTER TO EPA DATED JUNE 11, 2012, ELECTRO CHEMICAL DISCLOSED THAT THE FACILITY HAD FAILED TO SUBMIT TRI FORM R FOR TRICHLOROETHYLENE PROCESSED OR OTHERWISE USED FOR THE 2010 REPORTING YEAR, AS REQUIRED BY SECTION 313 OF EPCRA. THE TOTAL GRAVITY-BASED CIVIL PENALTY FOR THE VIOLATION, CALCULATED IN ACCORDANCE WITH EPA PENALTY POLICIES, WOULD BE $6,841. HOWEVER, ELECTRO CHEMICAL SATISFIED ALL OF THE CONDITIONS OF EPAÂS SMALL BUSINESS POLICY AND THE AMOUNT OF ECONOMIC BENEFIT GAINED WAS INSIGNIFICANT; THEREFORE, EPA WAIVED THE GRAVITY-BASED CIVIL PENALTY FOR THE DISCLOSED VIOLATIONS.