On November 19, 2011 the Respondent submitted to EPA Region 2 under the Audit Policy a self disclosure for Clean Water Act Section 311J Spill Prevention Control Countermeasure Plan (SPCC) violation for failure to prepare a SPCC for three district shops and failure to provide secondary containment for a 275 gallon tank and sixty one 55-gallon drums of oil; for Safe Drinking Water Act Section 1421 Underground Injection Control (UIC) failure to inventory 3 injection wells; for Resource Conservation Recovery Act Section 9003 Underground Storage Tank (UST) failure to upgrade a 1,000 gallon underground storage tank for diesel fuel. Pursuant to the Audit Policy and based on information provided, EPA has determined that the Respondent meets the conditions of the Audit Policy for 100% elimination of the total gravity-based penalties. The Respondent corrected the violations that were disclosed on the November 19, 2011 Audit Policy request.