The company sent a letter of self-disclosure to the EPA on July 16, 2012, for Emergency Planning and Community Right to Know Act (EPCRA) Section 312 and 313, within the 21-day window allowed in the Audit Policy after discovery; and on August 6, 2012, within 60 days of the disclosure as required by the Audit Policy, Form R reports for copper for years 2006 through 2010 were submitted to the EPA. Each of these reports were over one year late.