QUAKER STATE DISCLOSE THE VIOLATIONS ON NOVEMBER 13, 1998. EPA HAS DETERMINED THAT THE PENNZOIL-QUAKER STATE IS NOT ELIGIBLE FOR A 100% CIVIL PENALTY MITIGATION UNDER THE EPA'S INCENTIVES FOR SELF-POICING: DISCOVERY, DISCLOSURE, CORRECTION, AND PREVENTION OF VIOLATIONS, 65 FED. REG. 19618 (APRIL 11, 2000) ( SELF-DISCLOSURE POLICY ) BECAUSE THE VIOLATIONS WERE NOT DETECTED THROUGH AN ENVIRONMENTAL AUDIT OR A COMPLIANCE MANAGEMENT SYSTEM. HOWEVER, PENNZOIL-QUAKER STATE IS ELIGIBLE FOR A 75% REDUCTION OF GRAVITY-BASED PENALTY. SUBJECT TO THE TERMS OF THIS NOTICE OF NONCOMPLIANCE, EPA DOES NOT INTEND TO PURSUE PENALTIES AT THIS TIME. SINCE THE VIOLATIONS OCCURRED IN 1994, THE 5-YEAR STATUTE OF LIMITATIONS HAS EXPIRED. THEREFORE, WE RECOMMEND RESOLVING THE SELF-DISCLOSURE THROUGH ISSUANCE OF A NOTICE OF NONCOMPLIANCE AND NOT ASSESSING A CIVIL PENALTY AGAINST PENNZOIL-QUAKER STATE FOR THE DISCLOSED VIOLATIONS.