A self-disclosure regarding violations at the Respondent's Lewis Plant was submitted to EPA on November 22, 2011. The disclosure indicated the Respondent failed to file timely Toxic Release Inventory (TRI) Form R reports as required by Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) for lead for calendar years 2006, 2007, 2008, 2009 and 2010. The required Form R reports were submitted to EPA on December 15, 2011.