A self-disclosure regarding violations at the Respondent's plant located in East Hanover, New Jersey was submitted to the U.S. Environmental Protection Agency (EPA) on July 21, 2015 pursuant to EPA's Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations, 65 FR 19618, April 11, 2000, effective May 11, 2000 (Audit Policy). The disclosure indicated that the company had failed to file timely TRI Form R reports for ammonia for
calendar years 2011, 2012 and 2013 as required by Section 313 of the Emergency Planning and Community Right-to-Know Act. The required Form R reports were submitted to the EPA on September 18, 2015. These violations are not eligible for penalty mitigation under EPA's Audit Policy because an enforcement action, specifically a Notice of Determination, was issued to this facility on August 16, 2013 for violations disclosed under the Audit Policy on June 28, 2013. The 2013 Notice of Determination constitutes a history of violation within three years of the voluntary disclosure
dated July 21, 2015.