6/5/02: ON MAY 28, 2002, REGION VII REFERRED VIOLATIONS SEL F-DISCLOSED BY TRUE MANUFACTURING CO., INC. (TRUE) PURSUANT TO THE FINAL POLICY STATEMENT, INCENTIVES FOR SELF-POLICING: DISCOVERY, DISCLOSURE, CORRECTION AND PREVENTION OF VIOLATI ONS (SELF DISCLOSURE POLICY). TRUE SELF-DISCLOSED VIOLATION S UNDER THE SOLID WASTE DISPOSAL ACT OF 1976, COMMONLY REFER RED TO AS THE RESOURCE CONSERVATION AND RECOVERY ACT, AS AME NDED BY THE HAZARDOUS AND SOLID WASTE AMENDMENTS OF 1984 (R CRA), AND THE FEDERAL WATER POLLUTION CONTROL ACT, COMMONLY REFERRED TO AS THE CLEAN WATER ACT (CWA) AT TRUE'S O'FALLON, MISSOURI, FACILITY. EPA REGION VII PREVIOUSLY REFERRED VIOLATIONS OF THE CLEAN A IR ACT AT TRUE'S O'FALLON, MISSOURI, FACILITY. SUBSEQUENT T O THAT REFERRAL, TRUE AND THE UNITED STATES ENTERED INTO SET TLEMENT DISCUSSIONS TO RESOLVE ALL OUTSTANDING CLAIMS AGAINS T TRUE. BECAUSE ALL CLAIMS ARE BEING NEGOTIATED TOGETHER FO R SETTLEMENT PURPOSES, REGION VII IS REFERRING THE SELF-DISC LOSED VIOLATIONS 6/5/02: FOR INCLUSION IN THE COMPLAINT TO BE FILED SIMULTAN EOUSLY WITH THE LODGING OF A CONSENT DECREE. TRUE MEETS EACH OF THE NINE CONDITIONS OF THE SELF-DISCLOSUR E POLICY FOR ELIMINATING THE TOTAL GRAVITY-BASED PENALTY FOR THESE VIOLATIONS THAT OTHERWISE MIGHT BE ASSESSED UNDER RCR A AND THE CWA. EPA REGION VII WILL NOT SEEK A GRAVITY-BASED PENALTY FOR THESE VIOLATIONS. THE