EPCRS Use by a Former Participating Employer

[JRG]

Company A (previously a subsidiary) was a participating employer in a 401k plan (Plan X), was later sold and set up its own Plan (Plan Y) and is now to be merged into its Parent Co.'s plan (Plan Z). It has been discovered plan X has qualification issues (non-amenders, etc.)....Is it possible (i.e., does Company A have the legal authority) to submit an EPCRS submission for itself regarding Plan X qualification failures? If not, how does Company A get rid of the nonqualification "taint" of Plan X?