On September 2, 2005 and subsequently on August 26, 2006, Sensormatic Puerto Rico, Inc. submitted a written and signed statement of voluntary disclosure to EPA, ) pursuant to EPAÂs Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations, 65 FR 19618, April 11, 2000, effective May 11, 2000 (Audit Policy). In the disclosure, Sensormatic sttaed that the facility had failed to file EPCRA Form R Toxic Release Inventory Reports for lead compounds for Reporting Years 2001, 2002, 2003 and 2004 and for diisocyanates for Reporting Years 2001, 2002, 2003, 2004 and 2005 in violation of 40 CFR Part 372. The facility had not been aware of the reduced thresholds for persistent biocummulative toxic (PBT) chemicals for lead compounds. The facility had not been aware of the category for diisocyanates compounds and had only looked at the amount of each individual compound when assessing threshold determinations. Sensormatic submitted Form R Reports for these compounds on September 2, 2005 and August 24, 2006 respectively.
A gravity-based penalty total of $167,266 could have been assessed for these non-reporting violations. The facility meets the conditions of the Audit Policy for 100% elimination of gravity-based penalties for these violations and an NOD had been prepared.