IMPROPER DISPOSAL OF PCBS. FAILURE TO SUBMIT EPCRA FORM R ON TIME FOR SEVERAL CHEMICALS U.S. EPA INSPECTED THE CLARIANT FACILITY IN MCHENRY, ILLINOIS ON MAY 18, 1997. AT THE TIME, THE FACILITY WAS KNOWN AS POLYMER COLOR OF NORTH AMERICA. POLYMER WAS SUBSEQUENTLY PURCHASED BY CLARIANT. THE INSPECTION REVEALED THAT CLARIANT SHOULD HAVE SUBMITTED TOXIC CHEMICAL RELEASE INVENTORY FORMS FOR LEAD IN 1993, 1994, AND 1995; FOR CHROMIUM COMPOUNDS IN 1993, 1994, AND 1995, AND FOR ZINC COMPOUNDS IN 1994 AND 1995. CLARIANT ULTIMATELY FILED THE NECESSARY REPORTS ON MARCH 1, 1999. EPA PROPOSED A $112,000 PENALTY FOR CLARIANT'S TARDY FILING OF THE REPORTS. IN LIEU OF FILING AN ANSWER, CLARIANT AGREED TO PAY A $99,000 PENALTY TO SETTLE THIS MATTER.