On December 9, 2011 and February 14, 2012, the Respondents had discovered possible violations at its facility, located within the ConocoPhillips Bayway Refinery to the U.S. Environmental Protection Agency (EPA), pursuant to EPAÂs Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations (Audit Policy). Violations disclosed concerned the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 311 and 312 (Material Safety Data Sheets and inventory of chemicals respectively). Failure to file Tier 2 reports for sulfur hexafluoride. All violations were remedied. Pursuant to the Audit Policy and based on information provided, we have determined that the two facilities meet the conditions of the Audit Policy for 100% elimination of the total gravity-based penalties.