ON DECEMBER 22, 1999, SAPUTO NOTIFIED EPA THAT IT INTENDED TO CONDUCT AN INTERNAL AUDIT OF ALL ITS PLANTS TO EVALUATE THE COMPANY'S PRESENT AND HISTORICAL COMPLIANCE WITH EPCRA AND THE REQUIREMENTS RELATED TO THE CWA, SPECFICALLY SPCC PLANS AND SWPPP. ON FEBRUARY 18, 2000, SAPUTO SUBMITTED A LETTER TO EPA THAT PROVIDED THE INITIAL RESULTS OF THIS AUD. ON MAY 26, 2000, SAPUTO SUBMITTED ITS FINAL AUIDT REPORT TO EPA. IN THE LETTER DATED MAY 26, 2000, SAPUTO REPORTED THAT IT HAD DISCOVERED NONCOMPLIANCE WITH EPCRA AT 18 FACILITIES, NONCOMPLIANCE WITH CWA SPCC REQUIRMENTS AT 4 FACILITIES, AND NONCOMPLIANCE WITH CWA SWPPP REQUIREMENTS AT 10 FACILITIES.