ON 9/29/2005, EPA ISSUED A NOTICE OF DETERMINATON ( NOD ) PURSUANT TO EPA'S SMALL BUSINESS COMPLIANCE POLICY. THE NOD IS BASED ON SELF-DISCLOSURES PROVIDED BY H&N PACKAGING, INC. ( H&N ) FOR VIOLATIONS OF SECTION 313 OF EPCRA AT ITS FACILITY LOCATED AT 92 COUNTY LINE ROAD, COLMAR, PENNSYLVANIA. H&N DISCLOSED BY LETTERS DATED AUGUST 15, 2005 THAT IT HAD FAILED TO SUBMIT TOXIC RELEASE INVENTORY FORMS ( FORM R ) FOR METHYL ISOBUTYL KETONE FOR REPORTING YEAR 2003. THE TOTAL GRAVITY-BASED CIVIL PENALTY FOR THESE VIOLATIONS WOULD BE $21,922. HOWEVER, BECAUSE H&N SATISFIED ALL OF THE CONDITIONS OF EPA'S SMALL BUSINESS COMPLIANCE POLICY AND THE ECONOMIC BENEFIT IS INSIGNIFICANT, EPA WAIVED THE GRAVITY-BASED CIVIL PENALTY FOR THE DISCLOSED VIOLATIONS.