In response to the letter of inquiry sent to the company August 31, 2005 as part of the New Jersey Right to Know Program Initiative, Potters Industries Inc. voluntarily disclosed that they had failed to file Form R reports in a timely manner for copper, nickel, silver and nitrate compounds for calendar years 2002, 2003 and 2004 and requested relief for any associated penalties under the Audit Policy. The failure to submit a Form A or Form R report in a timely manner, constitutes a violation of Section 313 of the Emergency Planning and Community Right-to-Know-Act of 1986 (EPCRA), 42 U.S.C. §11023, and with 40 C.F.R. §372.30. The New Jersey Initiative offered companies the option of disclosing to the EPA under this policy.