IMPA HAS DISCLOSED POTENTIAL VIOLATIONS OF THE ACID RAIN PROGRAM. FACILITY SELF-DISCLOSED VIOLATIONS, SO WE ONLY SOUGHT BEN, NO GRAVITY PORTION OF PENALTY. VIOLATIONS INCLUDED; FAIL- URE TO SUBMIT ACID RAIN PERMIT ON TIME; FAILURE TO MONITOR SO2, NOX, AND CO2 EMISSIONS ON TIME, FAILURE TO SUBMIT A NOX AND SO2 MONITORING PLAN ON TIME, AND FAILURE TO SUBMIT QUARTERLY REPORTS UNTIL THIS YEAR. ANY EMISSION REDUCTIONS OR ELIMINATIONS WOULD BE SPECULATIVE, SO NONE INCLUDED.