Methodology question

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I asked a similar question before but I think the question was too hypothetical so here is a real scenario:

Employer discovers that for a large group of employees it has failed to count a certain bonus payment that was clearly covered under the plan's definition of pay.

This failure occurred in 1998, 1999, and 2000. Assume the employer has determined that in the aggregate this failure is significant.

The question is this: Am I precluded from self-correction because the initial failure occurred in 1998, outside the 2 year correction period? Or can I still self correct 1999 and 2000, and then "revisit" whether the 1998 portion alone is still "signficant?"

I think Rev. Proc. 2001-17's discussion of multiple defects and aggreation of defects is unclear.

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