The disclosure indicated that the company had commenced a self-audit concerning its regulatory obligations under Section 313 of the Emergency Planning and Community Right-to-Know Act regarding the lead containing scrap metal that the facility sends off-site for recycling. As a result of the audit, it was determined the company was required to file Toxic Release Inventory (TRI) Form R reports for chromium, copper and lead for calendar years 2010, 2011 and 2012 and for lead and chromium in calendar year 2009. The required TRI Form R reports for these chemicals and years have been submitted to EPA. The 2012 TRI Form R reports were filed in a timely manner.