On July 17, 2003, CHI Overhead Doore (CHI) in Arthur, IL disclosed to US EPA that CHI had failed to file Form R's as required by Section 313 of EPCRA for diisocyanates ( achemical category) for calendar years 1998, 1999, 2000 and 2001; manganese for calendar years 1998, 1999, 2000 and 2001; and nickle for calendar years 1998, 1999, 2000, and 2001. After investigating how that CHI determined that these violation occurred, it was found that CHI had not used the best unformation in its possession. US EPA provided compliance assistance. After reevaluation of the company's data, the company found that there were only 2 violations -failure to file Form R's for diisocyanates for calendar years 2000 and 2001. The facility filed the delinquent Form R's for diisocyanates at the time of making the disclosure to US EPA. The company did not discover the violations throught an audit or through the functioning of a compliance management system, but met the other 8 criteria of the Self-Policing Policy. Therefore the gravity based penalty was reduced 75% to $9, 350. The company did not receive any economics benefit from the violation.