United States Enforcement and EPA 300-N-98-003 

Environmental Protection Compliance Assurance March 1998 

Agency (2201A) 

Audit Policy Update 

Volume 3 Number 1 Office of Regulatory Enforcement March 1998 

GTE CORRECTS 600 VIOLATIONS THROUGH


EPA’S SELF-DISCLOSURE POLICY


In the biggest settlement reached under the EPA’s Audit Policy, EPA and GTE 

Corporation have come to an agreement 

that recognizes GTE’s cooperation in disclosing and resolving 600 violations at 

314 GTE facilities in 21 states. 

The violations occurred under the 

Emergency Planning and Community 

Right to Know Act (EPCRA) and the Spill 

Prevention Countermeasure and Control 

(SPCC) requirements of the Clean Water Act (CWA). 

The settlement represents the largest 

number of sites addressed in a single 

settlement using the Agency’s 

self-disclosure policy, which became 

effective January 1996. The settlement 

also demonstrates the policy’s broad 

scope in promoting compliance at facilities nationwide. 

“GTE is very pleased to have 

resolved these violations detected 

during an internal review of the 

company’s operations. The Policy 

is straightforward, easy to 

comprehend and it reinforces for 

the industry the advantage of selfpolicing.” 

Sheila Harvey 

Shaw, Pittman, Potts &Trowbridge 

GTE disclosed 511 violations of 

EPCRA (failure to notify state agencies 

and local fire departments of sulfuric acid 

filled batteries at 229 GTE telecommunications sites across the country) and 

SENATE HEARS TESTIMONY ON 

EPA’s AUDIT POLICY 

Steve Herman, EPA’s Assistant Administrator for Enforcement and Compliance Assurance, testified before the Senate’s Committee on Environment and Public Works along with industry, state, and public interest group 

representatives Oct. 30. 

The testimony focused on EPA’s progress in implementing its Audit 

Policy and whether federal legislation establishing audit privileges 

and/or immunities is desirable or necessary. 

In his testimony, Mr. Herman reiterated EPA’s longstanding opposition 

to such secrecy and amnesty legislation, and noted that EPA’s Audit Policy 

is working extremely well in encouraging audits, disclosures, and correction of violations. Herman mentioned the GTE settlement involving 

correction of 600 violations at 314 facilities, and the disclosures involving other companies, as evidence of this success. 

89 violations of the CWA (failure to develop required SPCC plans for diesel fuel 

stored at the facilities). SPCC plans are 

required to help prevent or mitigate spills 

and keep hazardous chemicals from polluting streams, rivers and other bodies of 

water. 

The settlement requires the company 

to pay a $52,264 penalty, equal to the 

amount of money saved by the company 

during its period of noncompliance. Of 

this amount, $16,708 is attributable to 

the CWA violations and $35,556 is for 

the EPCRA violations. In light of GTE’s 

outstanding cooperation in voluntarily 

disclosing and promptly correcting, the 

Agency, pursuant to the Audit Policy, 

waived another $2.38 million in potential penalties. 

Contents...


From the Assistant


Administrator................................ 2


Steel ‘Mini-Mills’ Encouraged to


Conduct Self-Audits ..................... 2


Voluntary Disclosure Board


Established for Disclosures


Involving Potential Criminal


Violations ..................................... 3


Companies Granted Audit Policy


Relief ............................................ 4


Small Business Policy Promotes


Assistance, Auditing..................... 6


Information Corner ....................... 7


See SENATE on page 2 

http://es.epa.gov/oeca/apolguid.html 
AUDIT POLICY UPDATE 

FROM THE ASSISTANT ADMINISTRATOR


EPA has opened the door for responsible companies 

working to stay in compliance with our environmental laws. 

Our Audit Policy slashes, and in some cases eliminates, 

penalties for those who voluntarily discover, promptly disclose and expeditiously correct violations, offering powerful incentives for the regulated community to comply. In 

addition to success under the Audit Policy, we have had 

good results in targeting specific requirements and offering 

one-time opportunities to report and correct violations in 

exchange for greatly reduced penalties. 

As of March 1, 247 companies have disclosed environmental violations under EPA’s Audit Policy at more than 

760 facilities nationally, and EPA has reduced or waived 

penalties under the policy for 89 companies at 433 facilities. Under our penalty cap initiatives, 89 companies took 

advantage of EPA’s one-time offer and submitted 11,000 

previously unsubmitted chemical risk studies to the Agency 

for review—more studies in this one TSCA 8(e) initiative 

than the total number of studies submitted to EPA since 

1978. 

Also in this issue, we report that 170 companies in the 

food manufacturing and processing industry submitted 

important information to the Agency and state and local 

emergency response personnel concerning hazardous 

chemicals stored onsite. As a result of this time-limited 

offer by EPA, we have obtained information that local 

communities need to effectively develop and implement 

emergency response plans for hazardous spills or releases, 

and enhance community awareness of the chemical hazards within the local area. 

Our results show that companies do not need secrecy or 

blanket immunity to meet their obligation to comply with 

our environmental laws. They do, however, respond well 

to fair and predictable incentives for voluntary compliance. Through our Audit Policy and penalty cap programs, we will continue to keep the door open for companies that want to walk through it. 

Steven A. Herman


Assistant Administrator for


Enforcement & Compliance Assurance


EPA OFFERS SELF-AUDIT INCENTIVES


TO STEEL ‘MINI-MILLS’


Early in fiscal year 1997, EPA’s Region 5 office in 

Chicago encouraged approximately two dozen small 

steel mills (“mini-mills”) in the Midwest to conduct 

self-audits and disclose potential environmental violations. Instead of conducting immediate inspections 

in this industry sector, EPA educated the regulated 

community on the applicable legal requirements and 

offered the mills an opportunity to take advantage of 

the Audit Policy before inspections planned for later 

in the fiscal year. Approximately half of the minimills conducted self-audits and several disclosed violations. EPA now has inspected most of the facilities 

that did not conduct a self-audit. 

For further information, contact 

Denny Dart at (312) 886-1426. 

SENATE FROM PAGE 1 

Even among the industry witnesses who testified in favor of 

federal privilege and immunity legislation, the Committee heard 

praise for EPA’s Audit Policy. Paul Wallach, a lawyer representing the National Association of Manufacturers (NAM) and 

the Corporate Environmental Enforcement Counsel (CEEC), 

remarked that EPA should be commended “for issuing its Audit 

Policy and for improving and clarifying the availability of penalty mitigation for responsible entities.” At the hearing, Wallach 

also told the Committee that EPA was doing a good job implementing its policy. When asked by the Senate Committee if 

there were any examples of EPA unfairly or poorly implementing its Audit Policy, Mr. Wallach and the other panelists identified none. 

According to Mr. Wallach, NAM’s more than 14,000 member companies and subsidiaries, which include approximately 

10,000 small manufacturers, are located in every state, industrial sector and produce approximately 85 percent of the goods 

manufactured in the United States. CEEC is an organization of 

22 diverse major companies, including numerous well-known 

Fortune 100 companies. 

Full copies of the written testimony submitted by Steve 

Herman, Paul Wallach and the other witnesses are available on 

the Internet at: 

http://www.senate.gov/~epw/stmts.htm 

2 February 1998 
AUDIT POLICY UPDATE 

Voluntary Disclosure Board Established for Disclosures


Involving Potential Criminal Violations


On Oct. 1, 1997, the Office of Criminal Enforcement, 

Forensics, and Training (OCEFT) issued a guidance entitled: 

“Implementation of the EPA’s Self-Policing Policy for Disclosures Involving Potential Criminal Violations.” 

This guidance establishes a Voluntary Disclosure Board 

(VDB) at OCEFT Headquarters in Washington, D.C., to ensure that all disclosures submitted to the Agency under the 

Self-Policing Policy involving potential criminal violations are 

considered and administered in a consistent and fair manner 

nationally, whether the initial disclosure is made to EPA regional offices, Headquarters or one of OCEFT’s 40 field offices of the Criminal Investigation Division (CID). 

The VDB or Board is comprised of OCEFT senior officials, as well as a member from the Environmental Crimes 

Section of the Department of Justice. The VDB dockets, 

monitors, and reviews all requests for treatment under the 

policy. Following review of the disclosure and the results of 

the criminal investigation, the Board will determine whether 

the relevant conditions of the policy have been satisfied and 

make a recommendation to the OCEFT director, who serves 

as the deciding official. The Director will decide if the agency 

should recommend whether the disclosing entity not be prosecuted. The final decision to accept the recommendation in 

criminal cases exclusively resides with the prosecuting authority in its independent exercise of prosecutorial discretion. 

The guidance further clarifies the conditions that are expected to be met by a disclosing entity in the criminal enforcement context, including the terms of cooperation with 

any government investigation and steps to assure correction, 

remediation and prevention of recurrence. The Board’s oversight will ensure that a criminal investigation initiated as a 

result of a disclosure has sufficient facts to support or oppose 

a recommendation that relief under the policy be granted. 

For further information contact


Michael Penders, OCEFT, (202) 564-2480.


Food Products Industry Gets Reduced Penalties For


Disclosing Chemical Inventory Violations


Federal, state and local agencies are 

now better prepared to handle emergencies, thanks to information about 

hazardous chemical inventories that 

nearly 200 food companies provided 

in response to a special EPA initiative. 

Through this initiative, the companies submitted previously required information about stored hazardous 

chemicals in response to a time-limited offer by EPA to reduce penalties 

for violations of the reporting requirements in the Emergency Planning and 

Community Right to Know Act 

(EPCRA). As of Feb. 1, 170 companies have submitted hazardous 

chemical data and paid individual fines 

of $2,000 (totaling $340,000), which 

is significantly less than they would 

have paid. 

The EPCRA hazardous chemical inventory report is due annually on 

March 1 to state emergency response 

commissions, local emergency planning committees and local fire 

departments. Data on hazardous 

chemical inventories provided by facilities are crucial for local communities to develop and implement emergency response plans effectively for 

hazardous spills or releases and to enhance community awareness of the 

chemical hazards within the local area. 

The food products sector was chosen because of the large number of 

facilities that store regulated quantities 

of hazardous chemicals, including 

ammonia, chlorine, and sulfuric and nitric acids. EPA first conducted compliance assistance, followed by this 

initiative for failure to submit hazardous chemical inventory information. 

This initiative is now concluded and 

the sector enforcement agreement is 

no longer available. EPA has established the EPCRA Hotline 

(1-800-424-9346) to provide free 

technical assistance to facilities. 

For further information, contact 

Dean Ziegel at (202) 564-4038 or 

Beth Burchard at (202) 564-4117. 

3 February 1998 
AUDIT POLICY UPDATE 

COMPANIES GRANTED AUDIT POLICY RELIEF


Acadia Polymers, Irongate, VA


Ademco, El Paso, TX


Alliant Techsystems, Inc., Toone, TN


ALCOA Fujikura Ltd., El Paso, TX


Alyeska Pipeline, Prudhoe Bay, AK (2 facilities)


Armstrong World Industries, Hilliard, OH


ATK North America, Arlington, TX


ARCO - Kuparuk Oil Field, Prudhoe Bay, AK


ARCO - Prudhoe Bay Oil Field, Prudhoe Bay, AK


Austin Sculpture, Pharr, TX


Auto Trim, Inc., Brownsville, TX


Baldwin Piano & Organ, Trumann,


Bortec Industrial Inc., El Paso, TX


BP Exploration - Duck Island Endicott, Endicott Island, AK


BP Exploration - Milne Point Unit, Milne Point, AK


BP Exploration - Sourdough Exploration, Sourdough, AK


BP Exploration - Western Oper. Unit, Prudhoe Bay, AK


BP Exploration & Oil, Inc., Houston, TX


BP Exploration & Oil, Inc., Port Angeles, WA


Burlington Northern Santa Fe, 4028 Deen Rd., Fort Worth, TX


Burlington Northern Santa Fe, 4200 Deen Rd., Fort Worth, TX


Burlington Northern Santa Fe, Silsbee, TX


Burlington Northern Santa Fe, Brownwood, TX


Burlington Northern Santa Fe, Temple, TX


Burlington Northern Santa Fe, Somerville, TX


Burlington Northern Santa Fe, Amarillo, TX


California Cooperative Creamery, Petaluma, CA


Carolina Power & Light, New Hill, NC


CENEX, Laurel, MT


CENEX, Denver, CO


CENEX, Inver Grove Heights, MN


CENEX, Rhame, ND


Chevron Chemical Company, San Ramon, CA


Citiplate, Inc., Jackson, TN


Clearwater Co., Pittsburgh, PA


Coilcraft, Inc., El Paso, TX


Cook Composites & Polymers, N. Kansas City, MO


Cook Inlet Pipe Line Co., Drift River, AK


DeKalb Genetics Corp, DeKalb, IL.


Emerson Electric Co., Paragould, AR


EPSON Portland, Inc., Hillsboro, OR


Fiber Resin Corp. (H.B. Fuller), Chatsworth, CA


Foster Products Corp. (H.B. Fuller), Houston, TX


Frederick Manufacturing Corp., Kansas City, MO


General Electric Corp., Waterford, NY


Gobar Systems, Inc., Brownsville, TX


Goulston Technologies, Inc., Monroe, NC


GTE Corporation, Stamford, CT (314 facilities in 21 States)


Hasbro, Inc., El Paso, TX


H.B. Fuller Company, Warren, MI


H.B. Fuller Company,Wilmington, MA


H.B. Fuller Automotive Products, Dayton, OH


H.B. Fuller R&D Pilot Facility, Vadnais Heights, MN


Invacare, Inc., McAllen, TX


ITT Automotive, Laredo, TX


Kaneka Texas Corp., Pasadena, TX


Kennecott Greens Creek Mining Co., Admiralty Island, AK


Kingsford Products, Inc., Louisville, KY


4 February 1998 

RC RA 9.0% 

EPC RA 61 .6% 

TSCA 5.3 % 

CWA 22.2% 

CAA 0.9% 

CERC 

SDW 

FIFRA 0.5 

����� ����������� ����������

■ Percentages reflect the number of facilities settling under the policy. 
5

AUDIT POLICY UPDATE

February 1998

Kinross Mining Company, Silver City, ID

Koch Refining Co., Corpus Christi, TX

Lambda Electronics, Inc., McAllen, TX

Lane Supply, Inc., Arlington, TX

Magnetek, Inc., Brownsville, TX

Metromedia Technologies, Inc., Los Angeles, CA

Microfoam Corp., Utica, NY

Midwestern Machinery, Minneapolis, MN

Mikron Industries, Inc., Kent, WA

Milliken & Company, Spartanburg, SC

Minolta Co., Ramsey, NJ

Mozel, Inc., St. Louis, MO

NCI Building Systems, Chester, SC

Norton Company, Stephenville, TX

Occidental Chemical Co., Pasadena, TX

Olin Corporation, East Alton, IL

O’Neill Industries, Philadelphia, PA

Outboard Marine Corp., El Paso, TX

Owens Corning, Amarillo, TX

Ozark-Mahoning Co., Tulsa, OK

Paramount Packaging Co., Longview, TX

Pete’s Refrigeration, Bluefield, WV

Pfizer, Inc., Lincoln, NE

Randall Manufacturing, Inc., Weidman, MI

Raychem Corp., Fuquay-Verina, NC

Reliable Pharmaceutical Corp., Overland, MO

Sampson Coatings, Richmond, VA

Shure Brothers, Inc., El Paso, TX

Siemens Electromechanical Co., El Paso, TX

Signet Graphics, St. Louis, 

Simplot Dairy Products, Nampa, ID

Audit Policy Update

Documents concerning the development of the Audit

Policy, settlements under the policy, and additional

copies of this Update, can be obtained by contacting

the Audit Policy Docket located in Room 4033 of the

Ariel Rios Building (1200 Pennsylvania Avenue, N.W.,

Washington, D.C.), by calling(202) 564-2119 or (202)

564-2614, or by Faxing requests to (202) 501-1011.

Solomon Corporation, Solomon, KS

Stepan Company, Millsdale, IL

Sunbeam-Oster Co., Bay Springs, MS

Sunbeam-Oster Co., Coushatta, LA

Sunbeam-Oster Co., Hattiesburg, MS

Sunbeam-Oster Co., McMinnville, TN

Sunbeam-Oster Co., Neosho, MO (2 facilities)

Sunbeam-Oster Co., Shubata, MS

Sunbeam-Oster Co., Waynesboro, MS

Teccor Electronics, Inc., Brownsville, TX

Thomson Saginaw Ball Screw, Saginaw, MI

Transportation Electronics, El Paso, TX

TRW Vehicle Safety Systems, McAllen, TX

TRW Automotive Products Remfg., McAllen, TX

Union Carbide Corp., Garland, TX

Union Carbide Corp., Hahnville, LA

Union Carbide Corp., Seadrfit Plant, TX

Union Carbide Corp., Texas City, TX (Main Plant) - #1

Union Carbide Corp., Texas City, TX (Main Plant) - #2

Union Carbide Corp., Texas City, TX (Marine Terminal)

Union Pacific Resources, Carthage, TX

University of Iowa, Iowa City, IA

Unocal Corp., Cook Inlet, AK

Vastar Resources, Inc., La Plata County, CO

Victoreen, Brownsville, TX

V-S Precision, El Paso, TX

Web Inks Ltd., Kennesaw, GA

Wells Manufacturing Co., McAllen, TX

Witco Corporation, Olathe, KS

Zeneca, Inc., Wilmington, DE

COMPANIES GRANTED AUDIT POLICY RELIEF

MO
AUDIT POLICY UPDATE 

EPA’s Small Business Policy Promotes


Compliance Assistance and Auditing


EPA’s Small Business Policy promotes environmental compliance by 

providing incentives, such as penalty 

waivers and penalty mitigation, to those 

small businesses that participate in 

onsite compliance assistance programs 

or conduct environmental audits to discover, disclose and correct violations. 

A small business may be eligible under the Agency’s “Policy on Compliance Incentives For Small Businesses” 

to have all potential penalties for noncompliance waived if the companies 

agree to come into compliance and 

meet other criteria. 

The Small Business Policy: 

•	 allows small businesses to get 

anonymous government-sponsored 

compliance assistance and still get 

penalty reductions or waivers if they 

disclose and correct their violations; and 

•	 provides an extended compliance 

period for small businesses that 

employ pollution prevention 

methods to correct their violations. 

Onsite compliance assistance includes information or assistance provided by EPA, a state or another government agency or government-supported organization during a visit to the 

facility to help the business comply 

with environmental requirements. 

States and EPA Regions may conduct 

compliance assistance visits or, through 

their compliance assistance programs, 

can identify other governmental organizations that provide onsite compliance assistance. 

To Whom Does the Policy Apply? 

The policy applies to a person, corporation, partnership, or other organization that employs 100 or fewer individuals. EPA will eliminate its penalty 

against the small business if: 

•	 the business receives onsite 

compliance assistance or conducts 

an environmental audit; 

•	 the business identifies the 

violation(s) through the assistance 

or audit, and discloses it within 10 

days (or such shorter period 

provided by law) to the appropriate 

government agencies; 

•	 it is the first violation of the 

requirement in a three-year period 

and no environmental enforcement 

actions against the business have 

been taken in the last five years; 

• the violation is corrected within 

•


180 days after detection of the 

violation (or 360 days if pollution 

prevention is employed); and 

the violation has not caused actual 

serious harm, and does not pose a 

potentially imminent and substantial 

endangerment to the public or 

environment, does not involve 

criminal conduct, and did not result 

in a significant economic benefit 

(which EPA anticipates will occur 

infrequently). 

EPA is marketing this easy-to-understand policy in a number of small business industry sectors, including dry 

cleaners and owners or operators of 

solvent cleaning machines that use particular halogenated solvents 

(degreasers). Other small businesses 

to which this policy may apply include, 

but are not limited to, industrial organic 

chemical manufacturers, the chemical 

preparations industry, construction, 

automotive service and repair shops, 

landowners/farmers, privately-owned 

drinking water systems, electroplaters, 

small quantity generators and fuel 

blenders. 

For further information on the 

policy contact Karin Leff at (202) 

564-7068. 

11,000 Risk Studies Submitted to EPA ies to the Agency for review. These previously unsubmitted 

studies more than total the number of studies submitted to Under Compliance Audit Program (CAP) the EPA since 1978. 

Eighty nine companies voluntarily reported possible violations The information provided in these studies is important to EPA in return for reduced civil penalties under the TSCA 8(e) because it provides EPA the information it needs to limit 

CAP initiative. or prohibit the use of chemicals that pose an unreasonable 

TSCA 8(e) requires chemical manufacturers to inform EPA of risk to health or the environment. EPA continues to evaluany information about mixtures or substances that may present “a ate the studies and is reviewing companies with similar prosubstantial risk of injury to health or the environment.” One hun- cesses to determine if they should be submitting 8(e) studdred and twenty-three companies undertook internal environmen- ies. 

tal audits under the initiative; 34 reported no 8(e) violations. For further information, contact 

The remaining 89 participating companies submitted 11,000 stud- Mark Garvey at (202) 564-4168. 

6 February 1998 
Audit Policy QRT Audit Policy QRT

AUDIT POLICY UPDATE 

INFORMATION CORNER


(clip and save) 

WHOM TO CALL FOR AUDIT POLICY RELIEF 

Regulated entities that wish to take advantage of the Policy should fax or send a written disclosure to the 

appropriate EPA contacts listed below. Note that the written disclosure must be made within 10 days of the 

violation’s discovery: 

EPA Office States Contact Phone # FAX # 

Region 1 (CT,ME,MA,NH,RI,VT) Suzanne Parent (617) 565-3351 (617) 565-1141 

Region 2 (NJ,NY,PR,VI) John Wilk (212) 637-3918 (212) 637-4035 

Region 3 (DE,DC,MD,PA,VA,WV) Samantha Fairchild (215) 566-2999 (215) 566-2905 

Region 4 (AL,FL,GA,KY, MS,NC,SC,TN) Bill Anderson (404) 562-9655 (404) 562-9663 

Region 5 (IL,IN,MI,MN,OH,WI) Tinka Hyde (312) 886-9296 (312) 353-1120 

Region 6 (AR,LA,NM,OK,TX) Barbara Greenfield (214) 665-2210 (214) 665-7446 

Region 7 (IA,KS,MO,NE) Becky Dolph (913) 551-7281 (913) 551-7925 

Region 8 (CO,MT,ND,SD,UT,WY) Michael Risner (303) 312-6890 (303) 312-6953 

Region 9 (AZ,CA,HI,NV) Leslie Guinan (415) 744-1339 (415) 744-1041 

Region 10 (AK,ID,OR,WA) Jackson Fox (303) 312-1073 (303) 312-0163 

HQ-Criminal Enf. All potential criminal violations Roy Kime (202) 564-2539 (202) 501-0599 

HQ-Multimedia Enf. Civil violations of >1 

EPA Statute in >1 EPA Region Melissa Marshall (202) 564-6002 (202) 564-9001 

HQ-Quick Response Team Civil violations in 

>1 EPA Region but under 

only one EPA statute Gary Jonesi (202) 564-4002 (202) 564-0011 

EPA HOMEPAGE 

http://www.epa.gov 

OECA HOMEPAGE 

http://es.epa.gov/oeca 

OECA POLICY & GUIDANCE 

http://es.epa.gov/oeca/polguid0.html 

AUDIT POLICY INTERPRETIVE GUIDANCE 

http://es.epa.gov/oeca/auditpol.html 

AUDIT POLICY 

http://es.epa.gov/oeca/apolguid.html 

SMALL BUSINESS POLICY 

http://es.epa.gov/oeca/smbusi.html 

WEBSITE INFO AUDIT GUIDANCE FOR CRIMINAL VIOLATIONS 

http://es.epa.gov./oceft 

Audit Policy QRT 

The Audit Policy “Quick Response Team” was developed to ensure that determinations for eligibility under the Audit Policy are quick, fair 

and consistent nationally. The QRT assists EPA regional offices, the Department of Justice and the public by interpreting the policy’s 

applicability, particularly in cases of first impression. The QRT is made up of senior staff from EPA Headquarters, Regions and the Department of Justice. The Audit QRT Chair is Gary Jonesi (202-564-4002). 

7 February 1998 
United States

Environmental Protection Agency

2201A

Washington, D.C. 20460

Official Business

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EPA

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The Audit Policy Update is published periodically for the Assistant Adminstrator for Enforcement and Compliance Assurance by its Office of

Regulatory Enforcement. pments

under the EPA Audit Policy. . Sarah

Weaver, weaver.sarah@epamail.epa.gov.

This publication is also available on the Internet at: http://es.epa.gov/oeca/apolguid.html

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