As a result of the 3M St. Paul Tape Plant CAFO in February 2003, 3M approached EPA to conduct a corporate audit of its refrigerant management practices at six facilities located across the country. 3M's assessment found Section 608 violations, mostly record-keeping violations. They have agreed to take actions to come into compliance and are conducting additional training of refrigerant technicians on EPA regulations and proper refrigerant management. Pursuant to EPA's Self-Disclosure Policy, penalties have been reduced to $0.