c/EPA
                        United States
                        Environmental Protection
                        Agency
                          Enforcement and
                          Compliance Assurance
                          (2201A)
              EPA300-N-98-003
              March 1998
Audit  Policy  Update
               GTE CORRECTS 600  VIOLATIONS THROUGH
                        EPA'S  SELF-DISCLOSURE  POLICY
  In the biggest settlement reached un-
der the EPA's Audit Policy, EPA and GTE
Corporation have come to an agreement
that recognizes GTE's cooperation in dis-
closing and resolving 600 violations at
314 GTE facilities in 21 states.
  The violations occurred under the
Emergency Planning and Community
Right to Know Act (EPCRA) and the Spill
Prevention Countermeasure and Control
(SPCC) requirements of the Clean Wa-
ter Act (CWA).

  The settlement represents the largest
number of sites addressed in a single
settlement  using  the  Agency's
self-disclosure policy, which became
effective January 1996. The settlement
also demonstrates the policy's broad
         scope in promoting compliance at facili-
         ties nationwide.

            "GTE is very pleased to  have
            resolved these violations detected
            during an internal review of the
            company's operations. The Policy
            is straightforward, easy to
            comprehend and it reinforces for
            the industry the advantage of self-
            policing."
                  Sheila Harvey
            Shaw, Pittman, Potts & Trowbridge

           GTE disclosed 511 violations of
         EPCRA (failure to notify state agencies
         and local fire departments of sulfuric acid
         filled batteries at 229 GTE telecommu-
         nications sites  across the country) and
89 violations of the CWA (failure to de-
velop required SPCC plans for diesel fuel
stored at the facilities). SPCC plans are
required to help prevent or mitigate spills
and keep hazardous chemicals from pol-
luting streams, rivers and other bodies of
water.
  The settlement requires the company
to pay a $52,264 penalty, equal to the
amount of money saved by the company
during its period of noncompliance. Of
this amount, $16,708 is attributable to
the CWA violations and $35,556 is for
the EPCRA violations. In light of GTE's
outstanding cooperation  in voluntarily
disclosing and promptly correcting, the
Agency, pursuant to the Audit Policy,
waived another $2.38 million in poten-
tial penalties.
              SENATE HEARS TESTIMONY ON
                    EPA's AUDIT POLICY
    Steve Herman, EPA's Assistant Administrator for Enforcement and Com-
  pliance Assurance, testified before the Senate's Committee on Environ-
  ment and Public Works along with industry, state, and public interest group
  representatives Oct. 30.
    The testimony focused on EPA's progress in implementing its Audit
  Policy and whether federal legislation establishing audit privileges
  and/or immunities is desirable or necessary.
    In his testimony, Mr. Herman reiterated EPA's longstanding opposition
  to such secrecy and amnesty legislation, and noted that EPA's Audit Policy
  is working extremely well in encouraging audits, disclosures, and cor-
  rection of violations.  Herman mentioned the GTE settlement involving
  correction of 600 violations at 314 facilities, and the disclosures involv-
  ing other companies, as evidence of this success.

                                      See  SENATE on page 2
                                              Contents...
                                           From the Assistant
                                           Administrator	
                                           Steel 'Mini-Mills' Encouraged to
                                           Conduct Self-Audits	
                                           Voluntary Disclosure Board
                                           Established for Disclosures
                                           Involving Potential Criminal
                                           Violations	
                                           Companies Granted Audit Policy
                                           Relief	4
                                           Small Business Policy Promotes
                                           Assistance, Auditing	6
                                           Information Corner	7
                                 http://es.epa.gov/oeca/apolguid.html

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                                      AUDIT POLICY UPDATE
                        FROM  THE ASSISTANT ADMINISTRATOR
   EPA has opened the door for responsible companies
 working to stay in compliance with our environmental laws.
 Our Audit Policy slashes, and in some cases eliminates,
 penalties for those who voluntarily discover, promptly dis-
 close and expeditiously correct violations, offering power-
 ful incentives for the regulated community to comply.  In
 addition to success under the Audit Policy, we have had
 good results in targeting specific requirements and offering
 one-time opportunities to report and correct violations in
 exchange for greatly reduced penalties.
   As of March 1,247 companies have disclosed environ-
 mental violations under EPA's Audit Policy at more than
 760 facilities nationally, and EPA has  reduced or waived
 penalties under the policy for 89 companies at 433 facili-
 ties. Under our penalty cap initiatives,  89 companies took
 advantage of EPA's one-time offer and submitted 11,000
 previously unsubmitted chemical risk studies to the Agency
 for review—more studies in this one TSCA 8(e) initiative
 than the total number of studies submitted to EPA since
 1978.
  Also in this issue, we report that 170 companies in the
food manufacturing and processing industry submitted
important information to the Agency and state and local
emergency response personnel concerning hazardous
chemicals stored onsite. As a result of this time-limited
offer by EPA, we  have  obtained information that local
communities need to effectively develop and implement
emergency response plans for hazardous spills or releases,
and enhance community awareness of the chemical haz-
ards within the local area.
  Our results show that companies do not need secrecy or
blanket immunity to meet their obligation to comply with
our environmental laws.  They do, however, respond well
to fair and predictable incentives for voluntary compli-
ance.  Through our Audit Policy and penalty cap pro-
grams, we will continue to keep the door open for compa-
nies that want to walk through it.

                                Steven A. Herman
                       Assistant Administrator for
            Enforcement & Compliance Assurance
  EPA OFFERS SELF-AUDIT INCENTIVES
          TO STEEL 'MINI-MILLS'
  Early in fiscal year 1997, EPA's Region 5 office in
Chicago encouraged approximately two dozen small
steel mills ("mini-mills") in the Midwest to conduct
self-audits and disclose potential environmental vio-
lations. Instead of conducting immediate inspections
in this industry sector, EPA educated the regulated
community  on the applicable legal requirements and
offered the mills an opportunity to take advantage of
the Audit Policy before inspections planned for later
in the fiscal year. Approximately  half of the mini-
mills conducted self-audits and several disclosed vio-
lations. EPA now has inspected most of the facilities
that did not conduct a self-audit.
         For further information, contact
          Denny Dart at (312) 886-1426
 SENATE FROM PAGE 1
   Even among the industry witnesses who testified in favor of
 federal privilege and immunity legislation, the Committee heard
 praise for EPA's Audit Policy.  Paul Wallach, a lawyer repre-
 senting the National Association of Manufacturers (NAM) and
 the Corporate Environmental Enforcement Counsel (CEEC),
 remarked that EPA should be commended "for issuing its Audit
 Policy and for improving and clarifying the availability of pen-
 alty mitigation for responsible entities." At the hearing, Wallach
 also told the Committee that EPA was doing a good job imple-
 menting its policy.  When asked by the Senate Committee if
 there were any examples of EPA unfairly or poorly implement-
 ing its Audit Policy, Mr. Wallach and the other panelists identi-
 fied none.
   According to Mr.  Wallach, NAM's more than 14,000 mem-
 ber companies and subsidiaries, which include approximately
 10,000 small manufacturers, are located in every state, indus-
 trial sector and produce approximately 85 percent of the goods
 manufactured in the United States. CEEC is an organization of
 22 diverse major companies, including numerous well-known
 Fortune 100 companies.
   Full copies of the written testimony submitted by Steve
 Herman, Paul Wallach and the other witnesses are available on
 the Internet at:
         http: //www. senate, go v/~ep w/stmts. htm
                                                                                            February 1998

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                                      AUDIT POLICY UPDATE
          Voluntary Disclosure Board
                       Involving Potential
  On Oct. 1, 1997, the Office of Criminal Enforcement,
Forensics, and Training (OCEFT) issued a guidance entitled:
"Implementation of the EPA's Self-Policing Policy for Disclo-
sures Involving Potential Criminal Violations."
  This guidance establishes a Voluntary Disclosure Board
(VDB) at OCEFT Headquarters in Washington, D.C., to en-
sure that all disclosures submitted to the Agency under the
Self-Policing Policy involving potential criminal violations are
considered and administered in a consistent and fair manner
nationally, whether the initial disclosure is made to EPA re-
gional offices, Headquarters or one of OCEFT's 40 field of-
fices of the Criminal Investigation Division (CID).
  The VDB or Board is comprised  of OCEFT  senior offi-
cials, as well as a member from the Environmental Crimes
Section of the Department of Justice.  The VDB dockets,
monitors, and reviews all requests for treatment under the
policy.  Following review of the disclosure and the results of
the criminal investigation, the Board will determine whether
the relevant conditions of the policy have been satisfied and
                Established for Disclosures
                Criminal Violations
                  make a recommendation to the OCEFT director, who serves
                  as the deciding official. The Director will decide if the agency
                  should recommend whether the disclosing entity not be pros-
                  ecuted. The final decision to accept the recommendation in
                  criminal cases exclusively resides with the prosecuting au-
                  thority in its independent exercise of prosecutorial discretion.
                    The guidance further clarifies the conditions that are ex-
                  pected to be met by a disclosing entity in the criminal en-
                  forcement context, including the terms of cooperation with
                  any government investigation and steps to assure correction,
                  remediation and prevention of recurrence. The Board's over-
                  sight will ensure that a criminal investigation initiated as a
                  result of a disclosure has sufficient facts to support or oppose
                  a recommendation that relief under the policy be granted.
                             For further information contact
                        Michael Fenders, OCEFT, (202) 564-2480.
                    Food Products Industry Gets Reduced Penalties For
                          Disclosing Chemical Inventory Violations
  Federal, state and local agencies are
now better prepared to handle emer-
gencies, thanks to information about
hazardous chemical inventories that
nearly 200 food companies provided
in response to a special EPA initiative.
  Through this initiative, the compa-
nies submitted previously required in-
formation about stored hazardous
chemicals in response to a time-lim-
ited offer by EPA to reduce penalties
for violations of the reporting require-
ments in the Emergency Planning and
Community Right to Know Act
(EPCRA).  As of Feb. 1, 170 com-
panies have submitted hazardous
chemical data and paid individual fines
of $2,000 (totaling $340,000), which
is significantly less than they would
have paid.
February 1998
  The EPCRA hazardous chemical in-
ventory report is due annually on
March 1 to state emergency response
commissions, local emergency plan-
ning committees and local  fire
departments.  Data on hazardous
chemical inventories provided by fa-
cilities are crucial for local communi-
ties to develop and implement emer-
gency response plans effectively for
hazardous spills or releases and to en-
hance community awareness of the
chemical hazards within the local area.
  The food products sector was cho-
sen because of the large number of
facilities that store regulated quantities
of hazardous chemicals,  including
ammonia, chlorine, and sulfuric and ni-
tric acids. EPA first conducted com-
pliance assistance, followed by this
initiative for failure to submit hazard-
ous chemical inventory information.
  This initiative is now concluded and
the sector enforcement agreement is
no longer available. EPA has estab-
lished  the   EPCRA  Hotline
(1-800-424-9346) to provide free
technical assistance to facilities.
 For further information, contact
Dean Ziegel at (202) 564-4038 or
Beth Burchard at (202) 564-4117.

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                                        AUDIT POLICY UPDATE
                      COMPANIES  GRANTED AUDIT POLICY RELIEF
Acadia Polymers, Irongate, VA
Ademco, El Paso, TX
Alliant Techsystems, Inc., Toone, TN
ALCOA FujikuraLtd., El Paso, TX
Alyeska Pipeline, Prudhoe Bay, AK (2 facilities)
Armstrong World Industries, Hilliard, OH
ATK North America, Arlington, TX
ARCO - Kuparuk Oil Field, Prudhoe Bay, AK
ARCO - Prudhoe Bay Oil Field, Prudhoe Bay, AK
Austin Sculpture, Pharr, TX
Auto Trim, Inc., Brownsville, TX
Baldwin Piano & Organ, Trumann,
Bortec Industrial Inc., El Paso, TX
BP Exploration - Duck Island Endicott, Endicott Island, AK
BP Exploration - Milne Point Unit, Milne Point, AK
BP Exploration - Sourdough Exploration, Sourdough, AK
BP Exploration - Western Oper. Unit, Prudhoe Bay, AK
BP Exploration & Oil, Inc., Houston, TX
BP Exploration & Oil, Inc., Port Angeles, WA
Burlington Northern Santa Fe, 4028 Deen Rd., Fort Worth, TX
Burlington Northern Santa Fe, 4200 Deen Rd., Fort Worth, TX
Burlington Northern Santa Fe, Silsbee, TX
Burlington Northern Santa Fe, Brownwood, TX
Burlington Northern Santa Fe, Temple, TX
Burlington Northern Santa Fe, Somerville, TX
Burlington Northern Santa Fe, Amarillo, TX
California Cooperative Creamery, Petaluma, CA
Carolina Power & Light, New Hill, NC
CENEX, Laurel, MT
CENEX, Denver, CO
CENEX, Inver Grove Heights, MN
CENEX, Rhame,ND
Chevron Chemical Company, San Ramon, CA
Citiplate, Inc., Jackson, TN
Clearwater Co., Pittsburgh, PA
Coilcraft, Inc., El Paso, TX
Cook Composites & Polymers, N. Kansas City, MO
Cook Inlet Pipe Line Co., Drift River, AK
DeKalb Genetics Corp, DeKalb, IL.
Emerson Electric Co., Paragould, AR
EPSON Portland, Inc., Hillsboro, OR
Fiber Resin Corp. (H.B. Fuller), Chatsworth, CA
Foster Products Corp. (H.B. Fuller), Houston, TX
Frederick Manufacturing Corp., Kansas City, MO
General Electric Corp., Waterford, NY
Gobar Systems, Inc., Brownsville, TX
Goulston Technologies, Inc., Monroe, NC
GTE Corporation, Stamford, CT (314 facilities in 21 States)
Hasbro, Inc., El Paso, TX
H.B. Fuller Company, Warren, MI
H.B. Fuller Company, Wilmington, MA
H.B. Fuller Automotive Products, Dayton, OH
H.B. Fuller R&D Pilot Facility, Vadnais Heights, MN
Invacare, Inc., McAllen, TX
ITT Automotive, Laredo, TX
Kaneka Texas Corp., Pasadena, TX
Kennecott Greens Creek Mining Co., Admiralty Island, AK
Kingsford Products, Inc., Louisville, KY
                                    Audit Settlements by Statute
                        Percentages reflect the number of facilities settling under the policy.
                                                                                              February 1998

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                                         AUDIT POLICY UPDATE
                       COMPANIES GRANTED AUDIT POLICY RELIEF
Kinross Mining Company, Silver City, ID
Koch Refining Co., Corpus Christi, TX
Lambda Electronics, Inc., McAllen, TX
Lane Supply, Inc., Arlington, TX
Magnetek, Inc., Brownsville, TX
Metromedia Technologies, Inc., Los Angeles, CA
Microfoam Corp., Utica, NY
Midwestern Machinery, Minneapolis, MN
Mikron Industries, Inc., Kent, WA
Milliken & Company, Spartanburg, SC
Minolta Co., Ramsey, NJ
Mozel, Inc., St. Louis, MO
NCI Building Systems, Chester, SC
Norton Company, Stephenville, TX
Occidental Chemical Co., Pasadena, TX
Olin Corporation, East Alton, IL
O'Neill Industries, Philadelphia, PA
Outboard Marine Corp., El Paso, TX
Owens Corning, Amarillo, TX
Ozark-Mahoning Co., Tulsa, OK
Paramount Packaging Co., Longview, TX
Pete's Refrigeration, Bluefield, WV
Pfizer, Inc., Lincoln, NE
Randall Manufacturing, Inc., Weidman, MI
Raychem Corp., Fuquay-Verina, NC
Reliable Pharmaceutical Corp., Overland, MO
Sampson Coatings, Richmond, VA
Shure Brothers, Inc., El Paso, TX
Siemens Electromechanical Co., El Paso, TX
Signet Graphics, St. Louis, MO
Simplot Dairy Products, Nampa, ID
                   Facilities Disclosing Violations
 350
Solomon Corporation, Solomon, KS
Stepan Company, Millsdale, IL
Sunbeam-Oster Co., Bay Springs, MS
Sunbeam-Oster Co., Coushatta, LA
Sunbeam-Oster Co., Hattiesburg, MS
Sunbeam-Oster Co., McMinnville, TN
Sunbeam-Oster Co., Neosho, MO (2 facilities)
Sunbeam-Oster Co., Shubata, MS
Sunbeam-Oster Co., Waynesboro, MS
Teccor Electronics, Inc., Brownsville, TX
Thomson Saginaw Ball Screw, Saginaw, MI
Transportation Electronics, El Paso, TX
TRW Vehicle Safety Systems, McAllen, TX
TRW Automotive Products Remfg., McAllen, TX
Union Carbide Corp., Garland, TX
Union Carbide Corp., Hahnville, LA
Union Carbide Corp., Seadrfit Plant, TX
Union Carbide Corp., Texas City, TX (Main Plant) - #1
Union Carbide Corp., Texas City, TX (Main Plant) - #2
Union Carbide Corp., Texas City, TX (Marine Terminal)
Union Pacific Resources, Carthage, TX
University of Iowa, Iowa City, IA
Unocal Corp., Cook Inlet, AK
Vastar Resources, Inc., La Plata County, CO
Victoreen, Brownsville, TX
V-S Precision, El Paso, TX
Web Inks Ltd., Kennesaw, GA
Wells Manufacturing Co., McAllen, TX
Witco Corporation, Olathe, KS
Zeneca, Inc., Wilmington, DE
                                                                   Audit Policy Update
                                                                   Documents concerning the development of the Audit
                                                                   Policy, settlements under the policy, and additional
                                                                   copies of this Update, can be obtained by contacting
                                                                   the Audit Policy Docket located in Room 4033 of the
                                                                   Ariel Rios Building (1200 Pennsylvania Avenue, N.W.,
                                                                   Washington, D.C.), by calling(202) 564-2119 or (202)
                                                                   564-2614, or by Faxing requests to (202) 501-1011.
         Energy   Communications    Chemical   Household Goods    Misc.
February 1998

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                                         AUDIT POLICY UPDATE
                            EPA's Small Business Policy Promotes
                             Compliance Assistance  and Auditing
  EPA's Small Business Policy pro-
motes environmental compliance by
providing incentives, such as penalty
waivers and penalty mitigation, to those
small businesses  that participate in
onsite compliance assistance programs
or conduct environmental audits to dis-
cover, disclose and correct violations.
  A small business may be eligible un-
der the Agency's "Policy on Compli-
ance Incentives For Small Businesses"
to have all potential penalties for non-
compliance waived if the companies
agree to  come into  compliance and
meet other criteria.
  The Small Business Policy:
•  allows small businesses to get
   anonymous government-sponsored
   compliance assistance and still get
   penalty reductions or waivers if they
   disclose and correct their viola-
   tions; and
•  provides an extended compliance
   period for small businesses that
   employ pollution prevention
   methods to correct their violations.
  Onsite compliance assistance  in-
cludes information or assistance pro-
vided by EPA, a state or another gov-
ernment agency or government-sup-
ported organization during a visit to the
facility to help the business comply
with environmental requirements.
States and EPA Regions may conduct
compliance assistance visits or, through
their compliance assistance programs,
can identify other governmental orga-
nizations that provide onsite compli-
ance assistance.
To Whom Does the Policy Apply?
  The policy applies to a person, cor-
poration, partnership, or other organi-
zation that employs 100 or fewer indi-
viduals. EPA will eliminate its penalty
against the small business if:
•  the business receives onsite
   compliance assistance or conducts
   an environmental audit;
•  the business identifies the
   violation(s) through the assistance
   or audit, and discloses it within 10
   days (or such shorter period
   provided by law) to the appropriate
   government agencies;
•  it is the first violation of the
   requirement in a three-year period
   and no environmental enforcement
   actions against the business have
   been taken in the last five years;
•  the violation is corrected within
   180 days after detection of the
   violation (or 360 days if pollution
   prevention is employed); and
•  the violation has not caused actual
   serious harm, and does not pose a
   potentially imminent and substantial
   endangerment to the public or
   environment, does not involve
   criminal conduct, and did not result
   in a significant economic benefit
   (which EPA anticipates will occur
   infrequently).
  EPA is marketing this easy-to-under-
stand policy in a number of small busi-
ness industry sectors, including dry
cleaners and owners  or operators of
solvent cleaning machines that use par-
ticular    halogenated   solvents
(degreasers). Other small businesses
to which this policy may apply include,
but are not limited to, industrial organic
chemical manufacturers, the chemical
preparations industry, construction,
automotive service and repair shops,
landowners/farmers, privately-owned
drinking water systems, electroplaters,
small quantity generators and fuel
blenders.
  For further information  on the
policy contact Karin Leff at (202)
564-7068.
  11,000 Risk Studies Submitted to EPA
  Under Compliance Audit Program (CAP)
    Eighty nine companies voluntarily reported possible violations
  to EPA in return for reduced civil penalties under the TSCA 8(e)
  CAP initiative.
    TSCA 8(e) requires chemical manufacturers to inform EPA of
  any information about mixtures or substances that may present "a
  substantial risk of injury to health or the environment." One hun-
  dred and twenty-three companies undertook internal environmen-
  tal audits under the initiative; 34 reported no 8(e) violations.
    The remaining 89 participating companies submitted 11,000 stud-
                     ies to the Agency for review. These previously unsubmitted
                     studies more than total the number of studies submitted to
                     the EPA since 1978.
                       The information provided in these studies is important
                     because it provides EPA the information it needs to limit
                     or prohibit the use of chemicals that pose an unreasonable
                     risk to health or the environment. EPA continues to evalu-
                     ate the studies and is reviewing companies with similar pro-
                     cesses to determine if they should be submitting 8(e) stud-
                     ies.
                              For further information, contact
                              Mark Garvey at (202)  564-4168.
                                                                                                February 1998

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                                       AUDIT POLICY UPDATE
                          INFORMATION  CORNER
                                              (clip and save)
WHOM TO CALL FOR AUDIT POLICY RELIEF
Regulated entities that wish to take advantage of the Policy should fax or send a written disclosure to the
appropriate EPA contacts listed below. Note that the written disclosure must be made within 10 days of the
violation's discovery:
EPA Office States Contact Phone # FAX #
Region 1 (CT,ME,MA,NH,PJ,VT)
Region 2 (NJ,NY,PR,VI)
Region 3 (DE,DC,MD,PA,VA,WV)
Region 4 (AL,FL,GA,KY,MS,NC,SC,TN)
Region 5 (IL,IN,MI,MN,OH,WI)
Region 6 (AR,LA,NM,OK,TX)
Region 7 (IA,KS,MO,NE)
Region 8 (CO,MT,ND,SD,UT,WY)
Region 9 (AZ,CA,HI,NV)
Region 10 (AK,ID,OR,WA)
HQ-Criminal Enf. All potential criminal violations
HQ-Multimedia Enf. Civil violations of >1
EPA Statute in >1 EPA Region
HQ-Quick Response Team Civil violations in
>1 EPA Region but under
only one EPA statute
Suzanne Parent
John Wilk
Samantha Fairchild
Bill Anderson
TinkaHyde
Barbara Greenfield
Becky Dolph
Michael Risner
Leslie Guinan
Jackson Fox
Roy Kime
Melissa Marshall
Gary Jonesi
(617) 565-3351
(212) 637-3918
(215) 566-2999
(404) 562-9655
(312) 886-9296
(214) 665-2210
(913) 551-7281
(303) 312-6890
(415) 744-1339
(303) 312-1073
(202) 564-2539
(202) 564-6002
(202) 564-4002
(617) 565-1141
(212) 637-4035
(215) 566-2905
(404) 562-9663
(312) 353-1120
(214) 665-7446
(913) 551-7925
(303) 312-6953
(415) 744-1041
(303) 312-0163
(202) 501-0599
(202) 564-9001
(202) 564-0011
                                          EPA HOMEPAGE
                                         http://www.epa.gov

                                         OECA HOMEPAGE
                                       http://es.epa.gov/oeca

                                     OECA POLICY & GUIDANCE
                                  http://es.epa.gov/oeca/polguidO.html
                   AUDIT POLICY INTERPRETIVE GUIDANCE
                     http://es.epa.gov/oeca/auditpol.html

                              AUDIT POLICY
                     http://es.epa.gov/oeca/apolguid.html

                          SMALL BUSINESS POLICY
                      http://es.epa.gov/oeca/smbusi.html
      WEBSITE  INFO
AUDIT GUIDANCE FOR CRIMINAL VIOLATIONS
          http ://es .epa.gov./oceft
                                          Audit Policy QRT
  The Audit Policy "Quick Response Team" was developed to ensure that determinations for eligibility under the Audit Policy are quick, fair
  and  consistent nationally.  The QRT assists EPA regional offices, the Department of Justice and the public by interpreting the policy's
  applicability, particularly in cases of first impression. The QRT is made up of senior staff from EPA Headquarters, Regions and the Depart-
  ment of Justice. The Audit QRT Chair is Gary Jonesi (202-564-4002).
February 1998

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    The Audit Policy Update is published periodically for the Assistant Adminstrator for Enforcement and Compliance Assurance by its Office of
    Regulatory Enforcement. The Update is intended to provide information to the public and regulated communities regarding developments
    under the EPA Audit Policy.  Editor: Virginia Bueno, (202) 564-8684. Email:  bueno.virginia@epamail.epa.gov. Graphic Artist: Sarah
    Weaver, weaver.sarah@epamail.epa.gov.
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 United States
 Environmental Protection Agency
 2201A
 Washington, D.C. 20460

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