THE FACILITY SELF-DISCLOSED TO THE EPA ON APRIL 2, 2001 AS A PART OF A SETTLEMENT WITH NYSDEC TO CONDUCT AN INDEPEN- DANT 3RD PARTY AUDIT. THE AUDIT WAS CONDUCTED SEPT 2, 2000, OCT. 3 AND OCT. 4, 2000. SUSPECTED EPCRA VIOLATIONS, AMONG OTHERS, WERE INDICATED IN A SUMMARY REPORT TO DEC IN A COR- RESPONDENCE DATED DEC. 20, 2000. THUS, THE FACILITY DID NOT MEET THE 21 DAY CRITERION OUTLINED IN THE AUDIT POLICY AND AS SUCH NO PENALTY RELIEF UNDER THE POLICY CAN BE GRANTED. THE COMPLAINT WAS ISSUED WITH A PENALTY OF $70,125 WHICH INCLUDED A 25% REDUCTION FOR VOLUNTARY DISCLOSURE.