On October 21, 2005, Tempil Inc. disclosed to EPA within 21 days of discovering that it had failed to submit Toxic Chemical Release Inventory Reporting Form R reports for lead compounds for reporting years 2001through 2004. The failures to submit in a timely manner complete and correct Form R or A reports for the listed toxic chemical, constitute failures to comply with Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), 42 U.S.C. § 11023, and with 40 C.F.R. § 372.30. A gravity-based penalty total of $20,307 could have been assessed for these non-reporting violations. The facility meets the conditions of the Audit Policy for 100% elimination of gravity-based penalties for these violations and an NOD had been prepared.