ON DECEMBER 9,2005, EPA ISSUED A NOTICE OF DETERMINATION ( NOD ) PURSUANT TO EPA'S SMALL BUSINESS COMPLIANCE POLICY. THE NOD IS BASED ON SELF-DISCLOSURES PROVIDED BY MI PRODUCTS, INC. ( MI PRODUCTS ) FOR VIOLATIONS OF SECTON 313 OF EPCRA AT ITS FACILITY LOCATED AT 404 UNION BOULEVARD, ALLENTOWN, PENNSYLVANIA. MI PRODUCTS DISCLOSED BY LETTER DATED AUGUST 11, 2005 THAT IT HAD FAILED TO SUBMIT TOXIC RELEASE INVENTORY FORMS ( FORM RS ) FOR NICKEL, CHROMIUM, COBALT, NITRATE COMPOUNDS AND NITRIC ACID FOR REPORTING YEARS 1999, 2000, 2001. HOWEVER, BECAUSE MI PRODUCTS 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 VIOLATION.