Office of Enforcement and 

Compliance Assurance (2248A) 

United States 

Environmental Protection Agency 

EPA 300-N-01-004 

AUDIT POLICY UPDATE 

Volume 5, Number 1 Office of Regulatory Enforcement Spring 2001 

Outreach Programs Expand Use of 

EPA’s Audit Policy 

2,000 Tons of Volatile Organic Compounds Reduced 

From Petroleum Above-Ground Storage Tanks 

Disclosures under EPA’s Audit Policy 

continued to reach record levels in 2000 

as the Agency promoted the disclosure and 

correction of violations in specific sectors. 

The Agency continues to promote 

compliance through the use of the Audit 

Policy, and has extended its applicability 

recently to a number of priority areas and 

sectors such as: 

� Above-ground storage tanks 

� Wetlands 

� Universities 

� Nitrate compounds 

� ‘Non-road’ engines 

� Grain producers 

� Telecommunications companies 

Results of Recent Audit Policy Programs 

✔Volatile Organic Chemicals Reduced: 2,021 Tons Annually 

✔Wetlands Acreage Restored: 2,000 plus 

✔TRI Reporting of Nitrate Compounds—Companies Reporting 1st 

Time or Correcting Form Rs: 135 

✔New Spill Prevention, Control and Countermeasure Plans: 246 

✔Sulfuric Acid, Diesel Fuel, Lead Reported to Emergency 

Responders: 5.5 Million Pounds 

✔Carbon Monoxide Reduced: 644 Tons Annually 

Snapshot 

� Airlines 

� Iron and steel ‘minimills’ 

In fiscal year 2000 alone, more than 425 

companies disclosed potential violations at 

nearly 2,200 facilities. More than 215 

companies corrected and received penalty 

relief for violations at approximately 435 

facilities in 2000, as well as 72 companies 

and 455 facilities in the first quarter of 2001. 

These numbers represent a continuing 

increase in the number of disclosures made 

annually under the Audit Policy. 

Since 1995, when the Audit Policy 

became effective, more than 1,150 

companies have disclosed potential 

Continued on page 2 

To expand its regulatory compliance incentives 

program, EPA recently 

revised 

disclosure policies, the Audit 

Policy 

Business 

Policy. 

After 

evaluation, EPA revised the 

policies based on extensive 

public outreach and the 

Agency's experience in 

handling self-disclosure 

cases. Businesses that meet 

policy conditions are eligible 

for penalty reductions and 

waivers and other benefits; 

however, both policies 

prohibit 

companies 

violations, such as those that 

may result in serious harm 

or risk, those that reflect 

repeated noncompliance, or 

those in which corporate 

officials condone criminal 

behavior. In addition, the 

policies allow A 

recover economic benefits 

from violating companies to 

ensure businesses that 

comply with environmental 

laws are not put at a 

competitive disadvantage by 

those not complying. 

Key revisions to the Audit 

Policy include lengthening 

the amount of time from 10 

to 21 days that entities have 

to disclose a violation after 

it is discovered; clarifying 

See ‘Policies Revised’ 

on page 2 

EPA Revises 

Audit, Small 

Business Policies 

its two selfand the Small 

Compliance 

a two-year 

benefits to 

for certain 

EP to 

This newsletter can be found on the Internet at http://www.epa.gov/oeca/ore/auditupd.html 
AUDIT POLICY UPDATE 

Continued from page 1 

violations at more than 5,400 facilities. 

1Above-ground Storage Tanks 

Under EPA’s Storage Tank Emission 

Reduction Partnership Program 

developed with the American Petroleum 

Institute (API), 61 companies 

nationwide have voluntarily agreed to 

install emission controls on 

approximately 866 above-ground 

storage tanks from 318 facilities. These 

emission controls are expected to 

reduce volatile organic compounds 

(VOCs) by 2,000 tons annually— 

equivalent to removing about 76,000 

cars from the nation’s roads. 

EPA believes that the joint program 

is an excellent example of how 

government and industry can work 

cooperatively to achieve significant 

environmental benefits. 

Companies participating in the 

Clean Air Act compliance incentive 

program include those with aboveground tanks that store substantial 

quantities of volatile organic liquids, 

including petroleum products (e.g., 

refineries, gasoline distribution 

terminals, chemical plants and other 

facilities). Under this cooperative 

program, companies agreed to install 

enhanced emission control devices on 

their above-ground storage tanks that 

are equipped with fittings called 

“slotted guidepoles.” 

Slotted guidepoles are slender 

columns built on the inside of the tank 

that run through the floating roof from 

the top to the bottom of the tank to 

prevent the roof from rotating. Slotted 

guidepoles have slots or perforations to 

allow for fuel sampling and drainage. 

While the guidepoles enable accurate 

sampling to be conducted for 

environmental compliance and product 

quality purposes, they also allow 

release of VOCs into the air. 

In return for companies’ 

participation, EPA agreed to eliminate 

any penalties from companies that 

agree to audit, disclose, and correct 

leaks from slotted guidepoles. 

Companies had until June 12 to register 

for the program and submit a 

participation agreement to EPA by Dec. 

11, 2000. Participating companies also 

agreed to install acceptable controls no 

later than June 13, 2002. More time will 

be allowed for those tanks that must be 

taken out of service to install these 

controls. 

The slots and the space between the 

guidepoles and the tank’s roof are 

observable emission pathways that 

violate the “no visible gap” prohibition 

in the Standards of Performance for 

Petroleum and Organic Liquid Storage 

Vessels (NSPS Subparts Ka and Kb). 

40 CFR 60.112a(a) and 60.112b(a). 

The petroleum industry conducted 

extensive research on emissions from 

slotted guidepoles and developed and 

tested the effectiveness of enhanced 

control technologies. EPA 

independently verified this research 

and mission estimate method and 

controls developed by API. 

Details of the compliance program 

were published in the Federal Register 

on April 13, 2000 (http://www.epa.gov/ 

fedrgstr/EPAFR-CONTENTS/2000/ 

AUDIT POLICY UPDATE 

April/Day-13/contents.htm). In a 

separate Jan. 14, 2000, Federal Register 

notice, EPA reaffirmed prior 

determinations that uncontrolled 

slotted guidepoles do not comply with 

the “no visible gap” requirement in 

Continued on page 3 

that a facility may qualify for Audit 

Policy credit even if another facility 

owned or operated by the same 

parent organization is already the 

subject 

investigation 

request; clarifying that companies 

will have at least 21 days to 

disclose violations discovered at 

newly-acquired facilities; and 

clarifying that the repeat violations 

will not disqualify newly-acquired 

facilities if the prior violations were 

not from the acquiring companies. 

The 

Compliance Policy, available for 

companies with 100 or fewer 

employees, reduces or waives 

penalties for small businesses that 

disclose and make good faith 

efforts to correct violations, 

provided they meet the criteria in 

the policy. The revised Small 

Business Compliance Policy 

lengthens the amount of time from 

10 to 21 days that entities have to 

disclose a violation after discovery; 

and expands the number of ways 

that 

discovered. Both policies were 

published in the April 11 Federal 

Register Notice (Vol. 65, No. 70), 

and took effect May 11 (see http:// 

www.epa.gov/oeca/polguid/ 

enfdock.html. 

Policies Revised/ 

from Page 1 

of an inspection, 

or information 

Small Business 

the violations can be 

The Audit Policy Update is published periodically by EPA’s Office of Regulatory Enforcement, Office of Enforcement 

and Compliance Assurance. The newsletter is intended to provide information to the public and regulated communities 

regarding developments under the EPA Audit Policy. Editor: Virginia Bueno, (202) 564-8684. Email: 

bueno.virginia@epa.gov. Co-Editor: Leslie A. Jones, (202), 564-5123; Email: jones.leslie@epa.gov. Change of address 

or subscription requests should be sent to the editor. Reproduction and wide dissemination of the newsletter are 

highly encouraged. 

Page 2 Spring 2001 
 AUDIT POLICY UPDATE 

Continued from page 2 

NSPS Subparts Ka and Kb (http:// 

www.epa.gov/fedrgstr/EPA-AIR/2000/ 

January/Day-14/a621.htm). Contact 

Mario Jorquera, EPA HQ, (202) 564-

1079. 

2Wetlands 

In January 2000, EPA Region 4 

and North Carolina’s Department of 

Environment and Natural Resources 

(DENR) initiated a Self-Audit/SelfDisclosure program to convince 95 

landowners who illegally ditched 11,400 

acres of wetlands to voluntarily restore 

their sites. EPA and DENR initiated this 

program because of limited staff 

resources and to provide an opportunity 

for violators to restore their illegally 

ditched wetlands with no monetary 

penalties. Region 4 and DENR 

published this initiative in local 

newspapers. 

Ten landowners agreed to 

participate in the self-audit program. 

These 10 sites comprised 

approximately 3,600 acres of illegally 

ditched wetlands. All but one site with 

nine acres of wetlands have been 

restored or are in the process of 

restoration. 

This program was a great success 

for EPA and DENR because more than 

31.5 percent of the total universe of 

illegally drained wetlands were restored 

as a result of this initiative. Contact 

Mike Wylie, EPA Region 4, (404) 562-

9409. 

3Universities 

EPA Regions 1, 2, 3 and 9 invited 

local universities to audit their 

laboratories and other facilities, and 

correct environmental violations in 

return for reduced penalties under the 

Audit Policy. During past inspections 

of university and college campuses 

across the nation, Regions have found 

significant noncompliance with the 

Resource Conservation and Recovery 

Act (RCRA); the Spill Prevention, 

Control and Countermeasure (SPCC) 

requirements of the CWA; underground 

storage tank management; and the 

CAA. 

Specific examples of 

noncompliance include improperly 

handling and disposing of hazardous 

waste materials; boilers and furnaces 

that do not meet clean air regulations; 

inadequate monitoring of underground 

storage tanks; sewage treatment 

facilities that are not operating 

How Do I Make a Voluntary Disclosure Under EPA’s 

Audit Policy? 

Once a violation has been discovered, a company has 21 days from the time of that discovery to disclose the violation to EPA. Companies should 

make the disclosure to the EPA Regional Office where the affected facility is 

located. In the event of violations affecting more than one Region, companies should contact Leslie Jones, EPA’s National Audit Policy Coordinator, at 

(202) 564-5123. 

The disclosure should identify the means of discovery, type of violation, 

facility location, and how it meets the conditions of the policy. EPA encourages companies to refer to the Optional Form for Disclosure Submittal 

(http://www.epa.gov/oeca/ore/checklist.pdf) to assist in determining what information EPA may seek about the violation(s). Documents concerning the 

development of the Audit Policy, settlements under the policy, and related 

publications can be obtained by contacting the Audit Policy Docket at (202) 

564-2119 or visiting http://www.epa.gov/oeca/polguid/enfdock/ 

docketC9401.html. 

properly; and improper abatement of 

lead-based paint and asbestos. 

As part of an integrated compliance 

strategy, Regions provided focus 

groups, compliance workshops and 

materials to numerous universities and 

colleges to ensure that these academic 

institutions are familiar with federal 

environmental requirements, and 

heightened their enforcement presence 

through on-site inspections. Contact 

Peggy Bagnoli, EPA Region 1, (617) 

918-1828. 

4Nitrate Compounds 

In April 2000, EPA launched a 

program to improve citizens’ right-toknow about harmful chemical 

compounds. After conducting outreach, 

workshops, and compliance assistance 

for industry, EPA identified facilities 

that reported the treatment of nitric acid 

over 18,000 pounds and failed to file 

the requisite Form R for nitrate 

compounds. 

The six primary industries 

responsible for most under/nonreporting were Fabricated Metals, 

Electronics, Food, Primary Metals, 

Transportation Equipment, and 

Chemicals. 

More than 600 facilities received 

letters in April 2000, explaining that 

EPA believed they were in violation. 

In the letter, EPA offered to settle 

violations for reduced penalties with 

companies that agreed to participate in 

a compliance incentive program. 

More than 300 companies that 

received the letter agreed to settle 

violations as proposed by EPA. 

Settlement agreements included a 

commitment to audit and to return more 

than 1,000 facilities to compliance with 

EPCRA Section 313. As a result, all 

participating facilities have certified full 

compliance with EPCRA Section 313 

Continued on page 4 

Spring 2001 Page 3 
AUDIT POLICY UPDATE 

Continued from page 3 

and submitted more than 9,000 late or 

corrected Form Rs.Contact Tom 

Marvin, EPA HQ, (202) 564-4282. 

5Non-road Engines 

In FY2000, EPA received 

disclosures affecting more than 2,200 

illegal nonroad engines. The CAA 

requires that nonroad engines imported 

into the United States display labels 

certifying that they meet federal 

emission standards. EPA investigations 

at several U.S. ports, conducted in 

cooperation with the U.S. Customs 

Service, suggest that a number of 

imported engines fail to meet these 

labeling requirements, and a subset are 

not meeting emission standards. These 

“gray market” engines undermine the 

nation’s air quality goals and put lawabiding equipment dealers at a 

competitive disadvantage. 

EPA has taken many steps to bring 

industry into compliance such as audit 

settlements with importers and 

responding to industry requests for 

increased enforcement against illegal 

imports. For first-time violators, EPA’s 

goal is to achieve a settlement that 

includes a requirement for the violator 

to conduct an audit and correct all prior 

You may receive an electronic subscription to Audit Policy 

Update by sending an email to: 

listserver@unixmail.rtpnc.epa.gov. 

1. Leave the subject line blank. 

2. Type the following in the body 

of the message: subscribe 

ocorelink our First Name 

Your 

3. Send the email with no further 

text in the body of the letter. 

Get This Publication 

Electronically! 

Y

Last Name 

violations of the regulations. 

All uncertified engines must be 

exported, but label violations may be 

corrected once EPA determines that the 

engine is certified. When uncertified 

engines are imported in equipment, the 

importers are required to correct 

violations by exporting the uncertified 

engines and providing a new certified 

replacement engine to the end user. 

Contact Mark Siegler, EPA HQ, (202) 

564-8673. 

6Grain Producers 

In November 2000, EPA Region 

7 issued letters to grain processing 

facilities inviting them to voluntarily 

audit for and correct violations of the 

CAA’s New Source Review (NSR)/ 

Prevention of Significant Deterioration 

requirements. 

Demand for products from this 

sector has steadily increased in the past 

decade. Existing facilities may have 

increased capacity by modifying 

process units or building new ones to 

meet this new demand. Increased 

capacity may trigger the need to obtain 

pre-construction permits under the 

CAA. 

Participants will have about six 

months to complete an air compliance 

audit and disclose any potential areas 

of noncompliance to EPA. 

Region 7 has identified the grain 

processing sector as an enforcement 

priority for 2001. EPA plans to increase 

overall inspections of grain processing 

facilities. Contact Jan Lambert, EPA 

Region 7, (913) 551-7003, 

7Telecommunications 

Industry 

In 2000, EPA continued to 

encourage telecommunications 

companies to voluntarily disclose and 

promptly correct compliance problems. 

In October, five companies 

disclosed 3,457 environmental 

violations from 1,122 of their facilities 

in 45 states and the District of 

Columbia. 

Under the proposed settlements, the 

companies will pay a total of $329,426, 

the amount saved by delaying 

compliance with EPCRA, SPCC 

requirements, CAA, and RCRA. The 

companies and their violations included: 

AirTouch Communications, Inc.; 

EPCRA and CWA SPCC; AT&T Corp.; 

CAA and SPCC; AT&T Broadband, 

LLC. EPCRA and SPCC; NEXTLINK 

Communication, Inc.; EPCRA, SPCC, 

CAA, and RCRA; and Qwest 

Communications International, Inc.: 

EPCRA, SPCC and CAA. 

Remedial actions for these 

companies' violations include notifying 

local emergency planning committees 

of the presence of hazardous chemicals, 

preparing spill prevention plans, 

applying for permits to construct or 

install standby generators, maintaining 

records for appliances containing more 

than 50 pounds of refrigerant, repairing 

refrigerant leaks from heating, 

ventilation and air conditioning units, 

and obtaining a letter of financial 

assurance demonstrating financial 

responsibility for corrective action or 

damage caused by sudden accidental 

releases from underground storage 

tanks. 

Since the outset of this initiative, 

EPA reached penalty settlements under 

its Audit Policy with 24 

telecommunications companies that 

voluntarily disclosed and corrected more 

than 6,200 environmental violations at 

more than 2,200 facilities. The 

companies received a 100 percent 

waiver of the gravity-based penalties, 

totaling more than $32 million, that 

otherwise could have been assessed. 

These companies paid approximately 

$607,000 in penalties in recent 

Continued on page 5 

Page 4 Spring 2001 
 AUDIT POLICY UPDATE 

Continued from page 4 

settlements—the amount of the 

economic benefit they realized through 

noncompliance. 

These responsible companies have 

ensured 246 facilities now have SPCC 

plans in place and have reported to 

emergency responders and planners 

more than 2.3 million pounds of diesel 

fuel, 2.1 million pounds of sulfuric 

acid, and 1.4 million pounds of lead 

present at their facilities. Contact Phil 

Milton, HQ, EPA, (202) 564-5029. 

8Airlines 

Following American Airlines’ 

voluntary disclosure of Clean Air Act 

fuel standards violations in 1999, EPA 

sent letters to all major domestic airlines 

inviting them to audit and self-disclose 

violations. The goal was to heighten the 

awareness of the airline industry’s 

environmental obligations to comply 

with CAA federal fuel standards, CWA 

storm water and spill prevention 

requirements, and EPCRA emergency 

releases reporting. In addition, EPA 

informed facilities of the availability of 

compliance information on the 

Transportation Environmental Resource 

Center (TERC) and provided highlights 

of applicable regulations to assist in 

I

f you have questions about EPA’s 

Audit Policy or its applicability to 

specific situations, contact EPA’s 

Audit Policy Coordinator, Leslie 

Jones, at (202) 564-5123. 

Questions may be asked without 

disclosing the name of the client 

or company. 

In A’s Quick 

Response Team (QRT) may be 

consulted as a resource for cases 

Questions About the Audit Policy? 

of first impression. Chaired by 

Leslie Jones, the QRT is made up 

of representatives from EPA 

Headquarters, Regions, and the 

Department of Justice. 

The QRT was developed to 

ensure that determinations for 

eligibility under the Audit Policy are 

expeditious, fair and consistent 

nationally. 

addition, EP

self-audits. 

Seven airlines and one fuel supplier 

self-disclosed violations, five of which 

were settled. EPA also initiated four 

other investigations against two airlines 

and their fuel suppliers. 

Last year, under the Agency’s Audit 

Policy, EPA and American Airlines 

(AMR Corporation) entered into a 

settlement that is expected to eliminate 

nearly 700 tons of pollutants from the 

air annually. American Airlines reported 

the use of a high-sulfur fuel in motor 

vehicles at 10 major airports around the 

country in violation of the Clean Air 

Act. Under the settlement, EPA cut total 

penalties by more than 90 percent for 

violations that the airline voluntarily 

disclosed and promptly corrected. The 

company also agreed to additional 

pollution reduction measures at Boston’s 

Logan Airport. Contact Jocelyn Adair, 

EPA HQ, (202) 564-1011. 

9Iron and Steel Minimills 

In August 2000, EPA sent letters to 

41 minimills inviting them to participate 

in a voluntary audit and self-disclosure 

program based on the Audit Policy. 

As a result of Agency investigations 

during the past few years, EPA has 

become increasingly concerned that 

serious, substantive violations of federal 

environmental regulations are occurring 

at some minimills. 

Companies that chose to disclose 

violations had until Feb. 28, 2001, to 

do so. Not all minimills were sent such 

letters—some were excluded from the 

program because of ongoing 

investigations and/or other enforcement 

activities. 

Minimills that received a letter were 

invited to perform an environmental 

audit of their facility to discover areas 

of noncompliance, and encouraged to 

consider taking advantage of EPA’s 

Audit Policy. 

Continued on page 8 

Facilities Disclosing Under EPA’s Audit Policy 

Spring 2001 Page 5 
AUDIT POLICY UPDATE 

EPA’s Office of Compliance has 

published nine environmental 

audit protocol manuals for businesses 

and organizations to perform 

voluntary environmental audits and 

disclose violations in accordance to 

EPA’s Audit and Small Business 

Policies. 

The audit protocols also provide 

technical guidance to regulated 

entities conducting environmental 

compliance audits and help ensure 

that audits are conducted in a 

thorough 

manner. Protocols are the principal 

working documents used by the 

auditor 

environmental compliance. EPA has 

produced audit protocols covering 

requirements under RCRA, CERCLA, 

EPCRA and portions of TSCA and 

SDWA. 

The protocols can be obtained 

through http://www.epa.gov/oeca/ 

ccsmd/profile.html The EPA Web site 

offers the protocols in both PDF and 

MS-Word formats. For greater 

flexibility, the word processing format 

allows the user to custom-tailor the 

protocols 

environmental aspects associated 

with the facility to be audited. 

Hard copies of the audit protocols 

can be obtained by contacting EPA’s 

National 

Environmental Publications (NSCEP) 

at 1-800-490-9198. For more 

information, 

Satterfield at EPA HQ at (202) 564-

2456. 

EPA’s Office of Compliance Publishes New 

Protocols to Aid Regulated Entities in 

Conducting Self-Audits 

and comprehensive 

to evaluate federal 

to more specific 

Service Center for 

contact Richard 

Audit Policy Online Resources


@ Audit Policy Information Homepage 

http://www.epa.gov/oeca/ore/apolguid.html 

@ Audit Policy: Incentives for Self-Policing 

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

@ Audit Policy Interpretive Guidance

(Questions and Answers) 

http://www.epa.gov/oeca/audpolguid.pdf 

@ ‘Audit Policy Update’ (Newsletter) 

http://www.epa.gov/oeca/ore/auditupd.html 

@	 Confidentiality of Information Received

Under Agency's Self-Disclosure Policy 

http://www.epa.gov/oeca/sahmemo.html 

@	 Memorandum--Subject: Implementation

of the Environmental Protection 

Agency's Self- Policing Policy for Disclosures Involving Potential Criminal 

Violations 

http://www.epa.gov/oeca/oceft/audpol2.html 

@	 Policy on Compliance Incentives For

Small Businesses 

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

@	 Memorandum--Subject: Reduced

Penalties for Disclosures of Certain Clean 

Air Act Violations 

http://www.epa.gov/oeca/ore/caa-tit.pdf 

@ Optional Form for Disclosure Submittal 

http://www.epa.gov/oeca/ore/checklist.pdf 

@ Audit Policy Evaluation 

http://www.epa.gov/oeca/oppa/ape.htm 

@ ‘Enforcement Alert’ (Newsletter) 

http://www.epa.gov/oeca/ore/enfalert 

Page 6 Spring 2001 
 AUDIT POLICY UPDATE 

Who to Contact to Make a Disclosure


Regulated entities that wish 

to take advantage of the policy should 

fax or send a written disclosure to the 

appropriate EPA contacts listed below. 

Written disclosure must be made 

within 21 days of the violation's 

discovery. 

��Region 1: Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont. 

Contact Joel Blumstein at (617) 918-1771; fax (617) 918-1809. 

��Region 2: New Jersey, New York and the territories of Puerto Rico and the U.S. Virgin Islands. 

Contact John Wilk at (212) 637-3918; fax (212) 637-4035. 

��Region 3: Delaware, Maryland, Pennsylvania, Virginia, West Virginia, and the District of Columbia. 

Contact Samantha Fairchild at (215) 814-2999; fax (215) 814-2905. 

��Region 4: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, and Tennessee. 

Contact Bill Anderson at (404) 562-9680; fax (404) 562-9663. 

��Region 5: Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin. 

Contact Tinka Hyde at (312) 886-9296; fax (312) 353-4135. 

��Region 6: Arkansas, Louisiana, New Mexico, Oklahoma, and Texas. 

Contact Charles Sheehan at (214) 665-2228; fax (214) 665-2146. 

��Region 7: Iowa, Kansas, Missouri, and Nebraska. 

Contact Becky Dolph at (913) 551-7281; fax (913) 551-7925. 

��Region 8: Colorado, Montana, North Dakota, South Dakota, Utah, and Wyoming. 

Contact David Rochlin at (303) 312-6892; fax (303) 312-6339. 

��Region 9: Arizona, California, Hawaii, and Nevada, and the territories of Guam and American Samoa. 

Contact Dan Reich at (415) 744-1343; fax (415) 744-1041. 

��Region 10: Alaska, Idaho, Oregon, and Washington. 

Contact Jackson Fox at (206) 553-1073; fax (206) 553-0163. 

�� HQ Criminal Enforcement: Contact Jon Jacobs at (202) 564-4037; fax (202) 501-0599 (all potential criminal 

violations). 

��National Audit Policy Coordinator: Contact Leslie Jones at (202) 564-5123; fax (202) 564-0011 (civil violations in 

more than one EPA Region and policy questions). 

Spring 2001 Page 7 
United States

Environmental Protection Agency

Office of Regulatory Enforcement

(2248A)

1200 Pennsylvania Avenue, NW

Washington, DC 20460

Official Business

Penalty for Private Use $300

Audit Policy Update

Recycled/Recyclable. Printed with Soy/Canola Ink on paper that contains at least 30% recycled fiber

This year’s minimill program is the

most recent in a multi-year effort to

assist this sector in achieving

compliance. This focused effort began

in 1996, when EPA Region V

encouraged minimills to self-disclose

violations to the Agency to improve

compliance among the minimills within

its six states. The disclosures submitted

by the companies and the multimedia

inspections performed by Region V and

states revealed environmental concerns

involving uncollected K061 baghouse

dust, slag cooling water puddles, electric

arc furnace shop floor dust and

Continued from page 5 monitoring, reporting, and maintenance

requirements. Contact Michael

Calhoun, EPA HQ, (202) 564-6031.

Update: Pork Producers

In November 1998, EPA and the

National Pork Producers Council

(NPPC) agreed to a comprehensive

Clean Water Act Compliance Audit

Program. The Clean Water Act audit

program provides incentives for pork

producers to undertake voluntary

comprehensive on-farm environment

assessments by greatly reducing

penalties for any CWA violations that

are promptly disclosed and corrected

under this program.

Since the start of the program, EPA

has entered into a total of 239

agreements and received 154 reports

with no violations reported.

The NPPC, which represents pork

producers nationally, plans to have

independent auditors conduct audits

nationwide to improve environmental

management practices and assure

compliance with the CWA. Contact

Kate Anderson, EPA HQ, (202) 564-

4016.