The company voluntarily disclosed that it failed to timeley file under EPCRA 313 a Form R with the U.S. EPA and with the State of Illinois for lead for each of the calendar years 1998, 1999, 2000 and 2001 for its Orland Park, Il facility. The company filed the delinquent Form R's on December 4, 2003. Although the company has an ISO 14001 certification, all such programs lack an EPCRA 313 compliance component. Therefore the company meets all but the first of the 9 criteria in the U.S. EPA Self-Policing Policy. U.S. EPA agreed to forgive 100% of the gravity based penalty ($74, 800) and the company agreed to develop and submit for U.S. EPA approval an EPCRA 313 compliance program. There are stipulated penalties if the company fails to develop an appropriate compliance program in a timely fashion.