ON MAY 8, 2004, EPA ISSUED A CONSENT AGREEMENT AND FINAL ORDER ( CAFO ) PURSUANT TO THE FINAL POLICY STATEMENT ON INCENTIVES FOR SELF-POLICING: DISCOVERY, DISCLOSURE, CORRECTION, AND PREVENTION OF VIOLATIONS, 65 FED. REG. 19618 (APRIL 11, 2000). THE CAFO IS BASED ON SELF-DISLOSURES PROVIDED BY VOLVO TRUCKS NORTH AMERICA, INC. ( VTNA ), FOR VIOLATIONS OF SECTION 3002 OF THE RESOURCE CONSERVATION RECOVERY ACT ( RCRA ), 42 U.S.C. 6922 AND ITS IMPLEMENTING REGULATIONS AT 40 C.F.R. PART 265. THE VTNA FACILITY ISI LOCATED AT NEW RIVER VALLEY PLANT IN DUBLIN, VIRGINIA ( FACILITY ). IN A LETTER TO EPA DATED NOVEMBER 12, 2002, AND IN SUBSEQUENT LETTERS TO EPA, VTNA DISCLOSED THAT THE FACILITY HAD POTENTIAL RCRA VIOLATIONS SPECIFICALLY, VTNA FAILED TO MAINTAIN CERTIFICATION OF DESIGN OF TANK SYSTEM ANCILLARY EQUIPMENT IN VIOLATION OF 40 C.F.R. SECTION 265.192(a); FAILED TO PROVIDE SECONDARY CONTAINMENT FOR ANCILLARY TANK EQUIPMENT IN VIOLATION OF 40 C.F.R. SECTION 265.193(f); FAILED TO ENSURE PROPER USE OF SPILL CONTROL/OVERFILL ALARMS FOR ANCILLARY TANK EQUIPMENT IN VIOLATION OF 40 C.F.R. SECTION 265.194(b); FAILED TO CONDUCT DAILY INSPECTIONS OF TANK SYSTEM COMPONENTS IN VIOLATION OF 40 C.F.R. SECTION 265.195(a) AND (c) FAILED TO MONTHLY MONITOR VALVES AND PUMPS ON ITS PURGE RECOVERY SYSTEM IN VIOLATION OF 40 C.F.R. SECTION 265.1052 AND 40 C.F.R. SECTION 265.1057; FAILED TO MAINTAIN A SCHEMATIC DIAGRAM OF PAINT/PURGE SYSTEM IN VIOLATION OF 40 C.F.R. 265.1064(b); FAILED TO