1. VOLUNTARY DISCLOSURE PURSUANT TO THE EPA'S POLICY GUID- ANCE, INCENTIVES FOR SELF-POLICING: DISCOVERY, DISCLOS- URE, CORRECTION AND PREVENTION OF VIOLATION. 2. STRUCTURAL METALS, INC. (SMI - TEXAS) BILLY DWYER ROAD SEGUIN, GUADALUPE COUNTY, TEXAS 78155-0911 3. RESPONDENT, UNDER THE SELF-POLICING POLICY, DISCLOSED VIOLATIONS OF SECTION 111 OF THE CAA - 1) FAILURE PRIOR TO JAN. 28, 1999 TO SUBMIT EXCESS EMISSION REPORTS FOR MELT SHOP OPACITY OR FURNANCE STATIC PRESSURE AND FAN AMPS; VIOLATION OF SECTION 112 OF THE CAA - 2) FAILURE TO NOTIFY EPA IN ADVANCE OF DEMOLITION OF ON-SITE FACILI- TIES; VIOLATIONS OF SECTION 311(J) OF THE CWA - 3) SWPPP/ RCRA CONTINGENCY PLAN DEFICIENCIES; VIOLATIONS OF SECTION 3005 OF RCRA - 4) IMPROPER LABELING OF USED OIL TANKS, 5) IMPROPER LABELING FOR UNIVERSE WASTE, AND 6) IMPROPER LABELING FOR SATELLITE ACCUMULATION DRUM AT THE REVERSE AIR BAGHOUSE; AND VIOLATION OF SECTION 6E OF TSCA - 7) FAILURE TO DOCUMENT STORAGE OF PCB CAPACITORS FOR LESS THAN 30 DAYS. 4. RELIEF SOUGHT PURSUANT TO THE SELF-POLICING POLICY, EPA WILL REVIEW THE RESPONDENT'S DISCLOSURE, CORRECTION AND PREVENTION OF RECURRENCE OF VIOLATIONS, AND PAST COMPLI- ANCE HISTIRY, AND MAKE A DETERMINATION AS TO THE RESPOND- ENT'S QUALIFICATION TO THE SELF-P