ON NOV. 1, 2000, ALUMINUM SHAPES, LLC. SUBMITTED A WRITTEN AND SIGNED STATEMENT OF VOLUNTARY DISCLOSURE TO EPA, STATING THAT THEY HAD DISCOVERED EPCRA SECTION 313 FORM R REPORTING VIOLATIONS. IN RESPONSE TO A TELEPHONE CONVERSATION WITH MR. JOHN WILKS OF THE EPA, ALUMINUM SHAPES, INC. FURTHER ELABORATED ON THE NATURE OF THE VIOLATIONS IN A LETTER DATED NOV. 22, 2000 IN WHICH THE CO. STATES THAT THEY FAILED TO FILE THE FOLLOWING EPCRA FORM R TOXIC RELEASE INVENTORY REPORTS IN A TIMELY MANNER: - DIISOCYANATES FOR CALENDAR YEARS 1995, 96, 97, 98, AND 99 - GLYCOL ETHERS FOR CALENDAR YEARS 1995, 96, 97, 98, AND 99 - COPPER FOR CALENDAR YEARS 1995, 1996, 1997, 1998, AND 99 - CHROMIUM COMPOUNDS FOR CALENDAR YEARS 1998 AND 1999 * BASED ON INFORMATION PROVIDED BY THE CO., WE BELEIVE THAT THEIR APPLICATION FOR 100% MITIGATION IS VALID, BECAUSE THE REQUIREMENTS OF CONDITIONS D.1 THRU D.7 OF THE AUDIT POLICY APPEAR TO HAVE BEEN MET. BASED ON THIS DETERMINATION, WE RECOMMEND THAT NO MONETARY PENALTY BE ASSESSED IN THIS CASE. ACCORDINGLY, WE SETTLED THE MATTER WITH NO PENALTY AND ISSUED A NOTICE OF DETERMINATION (ON 3/15/2001). *