A CACO WAS FILED ON NOVEMBER 3, 1993 CONCLUDING AN ENFORCE- MENT ACTION FOR VIOLATIONS OF EPCRA 313 AT THE SAME FACILITY FOR 1987, 1988, AND 1989. WTC IS INVOKING THE U.S. EPA AUDIT POLICY FOR VIOLATIONS OF EPCRA 313 FOR THE PAST 5 YEARS. VOLUNTARY DISCLOSURE MAY 14, 1999.