05/23/00 - AUDIT POLICY DISCLOSURE DATE. ON MAY 23, 2000 INDIUM DISCLOSED TO EPA THAT AT A EPA SPON- SORED TRI COMPLIANCE ASSISTANCE SEMINAR THE COMPANY DIS- COVERED THEY HAD INCORRECTLY CALCULATED LEAD RELEASES FOR TWO OF ITS FACILITIES LECATED N CLINTON, NY AND UTICA, NY, RESPECTIVELY. AS SUCH, THIS LEAD TO THE IMPROPER FILING OF A FORM A, WHEN A FORM R SHOULD HAVE BEEN FILED, FOR REPORT- ING YEARS 1995 THROUGH 1998. * ON MAY 23, 2000, INDIUM SUBMITTED A WRITTEN AND SIGNED STATEMENT OF VOLUNTARY DISCLOSURE TO EPA, STATING THAT THEY HAD BEEN INCORRECTLY FILING EPCRA FORM A TRI REPORTS FOR LEAD, IN LIEU OF FORM R, FOR REPORTING YEARS 1995 THROUGH 1998, AT TWO SEPARATE FACILITIES. NOTWITHSTANDING THE EX- PLICIT LANGUAGE IN THE REGULATION 40 CFR SECTION 372.27(A) THAT SPECIFIES THAT THE AMOUNTS TRANSFERRED FROM A FACILITY TO OFF-SITE LOCATIONS FOR RECYCLING PURPOSES IS INCLUDED IN THE COMBINED TOTAL QUANTITIES RELEASED, THE FACILITY HAD ERRONESOUSLY THOUGHT THAT SENDING SPENT MATERIALS CONTAINING LEAD OFF-SITE TO A METAL RECLAMATION FACILITY DID NOT COUNT AS A RELEASE. AND, WITHOUT INCLUDING THESE OFF-SITE TRANS- FERS, INDIUM THOUGHT THEY MET THE NECESSARY CRITERIA TO FILE A FORM A. IN THEIR DISCLOSURE, IT WAS EXPLAINED THAT ON MAY 4, 2000 REPRESENTATIVES FROM THE COMPANY ATTENDED AN EPA SPONSORED SECTION 313 TRI COMPLI