Vertex disclosed violations of the Toxic Substances Control Act (TSCA) section 8(a), 15 U.S.C. 2607(a), and the Inventory Update Reporting Regulations promulgated thereunder at 40 C.F.R. Part 710, when it failed to submit accurately a Data Production and Site Report (Form U) for chemical substances manufactured or imported at two of their facilities, as required for the 2006 Partial Updating of the TSCA Inventory