01/23/01 - DISCLOSURE DATE (AUDIT POLICY) * 3 TYPE CASES. *CCDS - ON 1/23/2001, UPR-AGUADILLA DISCOLOSED TO EPA A VIO- LATION OF FEDERAL ENVIRONMENTAL REQUIREMENTS. THE DISCLOSED VIOLATION INCLUDED THE FOLLOWING: (1) 40.CFR 262.11 - REQUIRES THAT A PERSON WHO GENERATES A SOLID WASTE, MUST DETERMINE IF THAT WASTE IS A HAZARDOUS WASTE. THE FACILITY DID NOT MAKE A DETERMINATION AS TO WHETHER ALL OF THE FACILITY'S WASTE FLUORESCENT LAMPS CON- STITUTED A HAZARDOUS WASTE. ON MARCH 9, 2001, EPA ISSUED NOTICE OF INCOMPLETE DISCLOSURE (NID) LETTER REQUESTING ADDITIONAL INFORMATION TO EVALUATE THE FULL REGULATORY AND COMPLIANCE STATUS OF UPD-AGUADILLA. ACCORDING TO DOCUMENTS SUBMITTED TO EPA BY UPR-AGUADILLA IN ITS APRIL 2, 2001, RESPONSE TO NID, THE FACILITY CORRECTED THE ABOVE VIOLATION AND INSTITUTED MEASURES INTENDED TO PRE- VENT RECURRENCE. BASED ON INFO SUPPLIED TO EPA BY UPR-AG, SOME WASTE FLUORESCENT LAMPS WERE NOT BEING MANAGED AS HAZ- ARDOUS OR UNIVERSAL WASTES. IN ADDITION, THE FACILITY HAS NO RECORD OF UNIVERSAL WASTE DISPOSAL FOR THE LAST THREE YEARS. * 02/12/2002 - NOTICE OF DETERMINATION ISSUED. *