A letter of voluntary self-disclosure was submitted to the US EPA on July 16, 2012 under the Audit Policy. The disclosure indicated that the Respondent had failed to file timely Toxic Release Inventory Form R reports for copper for calendar years 2006 through 2011. The required Form R reports were submitted to the EPA on August 6, 2012 as required by Section 313 of the Emergency Planning and Community Right-to-Know Act. The report for copper for year 2011 was submitted, in a timely manner, on July 2, 2012.