On November 22, 2010 and January 21, 2011, the Respondent self-disclosed under the Audit Policy for Emergency Planning & Community Right to Know Act (EPCRA). The facility failed to submit Tier 2 reports. Pursuant to the Audit Policy and based on information provided, EPA has determined that the facility meets the conditions of the Audit Policy for 100% elimination of the total gravity-based penalties. The Respondent corrected the violations that were disclosed on the November 22, 2010 Audit Policy request.