IN A LETTER TO EPA DATED JULY 13, 1999, HFD DISCLOSED TO EPA THAT DURING THE COURSE OF AN INTERNAL AUDIT, IT WAS DISCOVERED THAT THE FACILITY MAY HAVE VIOLATED THE REPORTING REQUIREMENTS BY FAILING TO REPORT THAT NITRAE COMPOUNDS IN EXCESS OF THE LIMIT COULD HAVE BEEN GENERATED FOR THE REPORTING PERIOD DATED 1995-1998 AS REQUIRED PURSUANT TO SECTION 313 OF EPCRA. IN A FOLLOW-UP LETTER TO EPA DATED 12/29/99, THE COMPANY'S REPRESENTATIVE STATED THAT ON 9/8/99, THE FORMS R'S FOR NITRATE COMPOUNDS WERE SUBMITTED FOR REPORTING PERIOD 1995-1998. THE VIOLATIONS WERE DISCOVERED BETWEEN JULY 5-9, 1999 AND DISCLOSED TO EPA ON 7/13/99, WELL WITHIN THE TEN REPORTING REQUIRMENT. CORRECTIVE ACTION WAS PROMPT IN THAT THE VIOLATION WAS CORRECTED WITHIN 60 DAYS OF DISCOVERY.