On December 30, 2004, EPA issued a Notice of Determination ( NOD ) based on self-disclosures provided by Hanson Pipe & Products, Inc. ( Hanson Pipe ) for violations of Section 313 of the EPCRA at nine facilities located in Maryland and Virginia. Hanson Pipe disclosed that it had failed to submit Toxic Release Inventory Forms ( Form Rs ) for Lead for the reporting years 2001 and 2002. The total gravity-based civil penalty for these violations would be $150,700. Since Hanson Pipe 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