On December 29, 2004, Region III issued a Notice of Determination ( NOD ) to Kidde Fire Fighting, Inc. ( KFF ) pursuant to EPA's (Self-Disclosure Policy ) is based on self-disclosures of violations of Section 313 of EPCRA at KFF's facility located at 2 Executive Way, Ranson, West Virginia. KFF disclosed that it had failed to report the use of copper and lead for the reporting years 1998, 1999, 2000, 2001, and 2002. The total gravity-based civil penalty for these violations would be $248,600.00. However, KFF satisfied all of the conditions of EPA's Self-Disclosure Policy and therefore EPA waived the gravity-based civil penalty for the disclosed violations. In addition, given that the amount of economic benefit gained was insignificant, EPA also waived the economic benefit penalty for the disclosed violations