On October 1, 2002, Roche submitted a voluntary disclosure pursuant to the Audit Policy, stating that they had failed to file EPCRA Form R Toxic Release Inventory Reports for nitrate compounds for calendar years 1995-2001. The Form R reports were submitted to the EPA on November 22, 2002. Upon review, it was determined that Roche did not meet Condition D.1 of the Audit Policy, Systematic Discovery. However, the disclosure did meet all the remaining conditions and Roche was therefore offered a 75% gravity penalty reduction for the violations, as provided under the Audit Policy. A CAFO (Docket number EPCRA 02-2003-4118) was subsequently executed on 7/7/03 for $21,544.