A letter of voluntary self-disclosure was sent on April 25, 2016 by the Respondent, on behalf of GH Berlin-Windward to the United States Environmental Protection Agency (EPA), pursuant to EPA?s Audit Policy and New Owner's Policy. On January 1, 2016, the Respondent acquired GH Berlin-Windward and its three sites located within Region 2. The East Syracuse, NY facility needed to file Form A reports for zinc compounds for calendar years 2011, 2012, 2013 and 2014. The Wilton, NY facility needed to file Form A reports for zinc compounds for calendar years 2012, 2013, and 2014. The Dover, NJ facility needed to file Form A reports for zinc compounds for calendar years 2011 and 2012. The Form A reports were submitted to EPA on May 6, 2016 as required by Section 313 of the Emergency Planning and Community Right-to-Know Act. The 2011, 2012, and 2013 reports were over one year late. The 2014 reports were 310 days late. EPA could have sought $211,900 for these non-reporting violations. These violations are eligible for 100% penalty mitigation under the EPA?s New Owner Policy.