On May 23, 2003 the facility disclosed to EPA that during a company audit at its facility in 2003 conducted by an outside environmental law firm it was discovered that it had failed to submit a timely complete and correct Toxic Chemical Release Inventory Reporting Form R report for processing approximately 1000 pounds of lead for calendar year 2001 as required by Section 313 of the Emergency Community Right-to-Know Act (EPCRA), 42 U.S.C. � 11023, and the Federal regulations that set out in greater detail the Section 313 reporting requirements, 40 C.F.R. Part 372. The established threshold amount for reporting the Persistent Bioaccumulative Toxic Chemical lead for the 2001 calendar year was 100 pounds. [40 C.F.R. �372.28] Under EPA�s Enforcement Response Policy (ERP) for Section 313 of EPCRA issued by the USEPA Office of Compliance Monitoring, Office of Pesticides and Toxic Substances on August 10, 1992 a gravity-based penalty total of $27,500 could have been assessed for this non-reporting violation.