THE CITY OF SYRACUSE DEPT OF PUBLIC WORKS HAD PREVIOUSLY SUBMITTED A DISCLSOURE AND WAS ISSUED A NOD. REGION 2 WAS UNDER THE MISTAKEN ASSUMPTION THE AUDIT WAS COMPLETED. HOWEVER, THE AUDIT CONTINUED AND POSSIBLE NON-COMPLIANCE FOR UNIVERSAL WASTE WAS REPORTED ON OCTOBER 15, 2008. THE FACILITY QUALIFIED FOR 100% MITIGATION OF GRAVITY BASED PENALTIES. ECONOMIC BENEFIT WAS INSIGNIFICANT.