On September 19, 2003, EPA issued a Notice of Determination (ANOD@) pursuant to the Self- Disclosure Policy to Spartech Polycom, Inc (ASpartech@). The NOD is based on self-disclosures provided by , for violations of Sections 313 of the Emergency Planning and Community Right- to-Know Act (AEPCRA@) 42 U.S.C. '11023, and its implementing regulations at 40 C.F.R. Part 372 at two of its facilities, located in Conshohocken, PA and Donora, PA. Spartech disclosed that it had failed to submit Toxic Chemical Release Inventory Forms (Forms R ) for antimony compounds, barium compounds, cadmium compounds, chromium compounds, lead compounds and zinc compounds for various reporting years during the time period of 1997 through 2001