Hydro is an aluminum processing company incorporated in Delaware, with its headquarters located at 801 International Drive, Suite 200, Linthicum, Maryland 21090. In May 2005, Hydro contacted EPA about auditing its facilities for potential violations of various environmental requirements at 16 Hydro facilities. From May 2005 until September 2007, pursuant to EPAÂs policy entitled Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations (Audit Policy), 65 Fed. Reg. 19,618 (April 11, 2000), Hydro submitted voluntary disclosures to EPA. Hydro disclosed potential violations of the following statutes and corresponding regulations:
a. Clean Air Act (CAA) § 112, 42 U.S.C. § 7412;
b. Clean Water Act (CWA) § 311, 33 U.S.C. § 1321;
c. CWA § 301, 33 U.S.C. § 1311;
d. CWA § 402, 33 U.S.C. § 1342;
e. CWA § 307, 33 U.S.C. § 1317;
f. Emergency Planning and Community Right-to-Know Act (EPCRA) § 312,
42 U.S.C. § 11022;
g. EPCRA § 313, 42 U.S.C. § 11023;
h. Resource Conservation and Recovery Act (RCRA) § 3002, 42 U.S.C. § 6922; and
i. RCRA § 3005, 42 U.S.C. § 6925.
The administrative settlement requires Hydro to pay a proposed civil penalty of $119,365 for all disclosed violations.