SELF-DISCLOSURE POLICY - VIOLATION OF EPCRA SECTION 313 - FAILURE TO FILE FORM R AND EPA & PENNSYLVANIA RE: NITRATE COMPOUNDS MANUFACTURED AT FACILITY ABOVE 25,000 POUNDS FOR EACH OF THE FOLLOWING CALENDAR YEARS - 1995, 1996, 1997 AND 1998. 100% MITIGATION OF GRAVITY BASED PENALTY OF $107,500. NOD ISSUED ON DEC. 28, 2000.