On September 28, 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.��� The NOD is based on self-disclosures provided by SEMCO INC for violations of Section 313 of EPCRA at its facility located at 7704 Enon Drive, Roanoke, Virginia.
SEMCO disclosed by letter dated June 16, 2004 that it had failed to submit Toxic Chemical Release Inventory Forms(Form R) for lead, chromium, copper, manganese and nickel for five reporting years, 1998 through 2002. The total gravity-based civil penalty for these EPRCA violations would be $114,835.00. However, because SEMCO satisfied all of the conditions of EPA���s Self-Disclosure Policy and the amount of economic benefit gained is insignificant, EPA waived the civil penalty for the disclosed violations.