The violations listed below were reported by McWane to the United States Department of Justice pursuant to an Environmental Audit Disclosure Agreement. Under the Agreement, McWane conducted an audit of all of its facilities, including the two facilities located in Region 3. McWane, through an independent auditor, visited each of the Region 3 facilities twice between 2001 and 2004. An audit report identifying alleged areas of noncompliance at the two Region 3 facilities was produced in 2005. EPA Region 3 personnel reviewed the report and conducted file reviews and inspections of the facilities. Discussions with EPA state regulatory counterparts also took place.