ON AUGUST 16, 1999, BROWN DISCLOSED TO EPA THAT DURING THE COURSE OF NEGOTIATING WITH CALDWELL TANKS, INC. WHO WAS IN THEPROCESS OF ACQUIRING TWO OF BROWN'S FACILITIES LOCATED IN NEWNAM, GA, IT WAS DISCOVERED THAT FORM R REPORTS FOR 1996, 1997, 1998, HAD NOT BEEN FILED WITH THE PROPER AGENCIES. IT WAS DURING THE PRE- ACQUISITION NEGOTIATIONS, THAT BROWN BECAME AWARE THAT IT WAS REQUIRED TO SUBMIT THE FORM R'S. ACCORDING TO BROWN'S AUGUST 16, 1999, DISCLOSURE LETTER TO EPA THE DISCOVERY OF THIS VIOLATION WAS MADE DURING THE COURSE OF A REVIEW OF ALL APPLICABLE ENVIRONMENTAL REGULATIONS IN PREPARATION OF PRE-ACQUISITION NEGOTIATIONS BETWEEN BROWN STEEL CONTRACTORS AND CALDWELL TANKS, INC. THE FACILITY SUBMITTED THE CORRECTED FORM R REPORTS TO THE EPCRA REPORTING CENTER AND THE GEORGIA EMERGENCY RESPONSE COMMISSION.