SCHREIBER FOODS FAILED TO REPORT THE MANUFACTURE OF NITRATE COMPOUNDS CREATED DURING TREATMENT PROCESSES THAT USED NITRIC ACID. DURING THE PREPARATION OF THEIR 1998 TRI REPORTS, SCHREIBER FOODS RECOGNIZED THAT THEY MAY BE GENERATING NITRATE COMPOUNDS OVER THE 25,000 LBS THRESHOLD AND SUBSEQUENTLY INFORMED EPA. THEY WERE ALLOWED A 100% MITIGATION OF THE PENALTY FOR HAVING SELF-DISCLOSED THEIR VIOLATION.