ON SEPTEMBER 27, 2004 EPA ISSUED A NOTICE OF DETERMINATION (NOD) PURSUANT TO THE FINAL POLICY STATEMENT ON INCENTIVES FOR SELF-POLICING: DISCOVERY, DISCLOSURE, CORRECTION, AND PREVENTION OF VIOLATIONS, 65 FED. REG. 19618 (APRIL 11, 2000). THE NOD IS BASED ON SELF-DISCLOSURES PROVIDED BY ATOGLAS DIVISION, ATOFINA CHEMICALS, INC ( ATOFINA ) FOR VIOLATIONS OF SECTION 313 OF THE EMERGENCY PLANNING AND COMMUNIT RIGHT-TO-KNOW ACT AT ITS FACILITY LOCATED AT 100 PA ROUTE 413, BRISTOL, PA 19007. ATOFINA DISCLOSED THAT IT HAD FAILED TO SUBMIT TOXIC RELEASE INVENTORY FORMS ( FORM Rs )FOR METHYL METHACRYLATE, ETHYL ACRYLATE, BUTYL ACRYLATE FOR THE REPORTING YEARS 2000, 2001 AND 2002. THE TOTAL GRAVITY-BASED CIVIL PENALTY FOR THESE VIOLATIONS WOULD BE $148,000. SINCE ATOFINA SATISFIED ALL OF THE CONDITIONS OF EPA'S SELF-DISCLOSURE POLICY AND THE AMOUNT OF ECONOMIC BENEFIT GAINED WAS INSIGNIFICANT, EPA WAIVED THE GRAVITY-BASED CIVIL PENALTY FOR THE DISCLOSED VIOLATIONS.