ON JULY 12, 2001, ECD DISCLOSED TO EPA THAT IT HAD DISCOVERED THAT TOXIC RELEASE INVENTORY FORM R REPORTS FOR NITRIC ACID, WATER DISSOCIABLE NITRATE COMPOUNDS AND ZINC COMPOUNDS SHOULD HAVE BEEN SUBMITTED FROM 1997 TO 1999 AND THAT THE REPORTS SUBMITTED FOR SULFURIC ACID, LEAD AND HYDROCHLORIC ACID WERE SUBMITTED IN ERROR FROM 1997 TO 1999. THE COMPANY DID NOT MEET THE REPORTING THRESHOLD FOR LEAD AND DID NOT MET THE ACID AEROSOL QUALIFIER FOR SULFURIC ACID AND HYDROCHLORIC ACID. ECD IS AWARE THAT UNDER THE NEW REPORTING THRESHOLD OF 100 LBS FOR LEAD THAT THEY WILL NEED TO REPORT FOR THE 2001 REPORTING YEAR. ADDITIONALLY, THE COMPANY SUBMITTED 11 REVISED FORM R REPORTS FROM 97 TO 1999 FOR CHROMIUN, NICKEL, MANGANESE, AND AMMONIA. *** THE ABOVE MENTIONED VIOLATIONS WERE DISCOVERED ON JUNE 28, 2001 DURING PREPARATION OF THE COMPANY'S TRI FROM R SUBMISSIONS FOR CALENDAR YEAR 2000, WHICH WERE PREPARED BY ECD'S CONSULTANT, KILAM ASSOCIATES. THE DISCLOSURE TO THE EPA WAS MADE 14 DAYS AFTER DISCOVERY UNDER THE SMALL BUSINESS POLICY. *