On November 15, 2010, Respondent self-disclosed possible violations at its facility in Valhalla, NY under the Audit Policy for Resource Conservation & Recovery Act (RCRA). The facility failed to characterize and manage hazardous wastes: pharmaceutical wastes, wastes disposed down drain, waste paints, thinners and lacquers, wastes in clinical labs and in the Microbiology Laboratory. Also other RCRA failures including labeling requirements for Universal Wastes and hazardous wastes and maintaining manifests properly. Pursuant to the Audit Policy and based on information provided, EPA has determined that the facility meets the conditions of the Audit Policy for 100% elimination of the total gravity-based penalties. Respondent corrected the violations that were disclosed on the November 15, 2010 Audit Policy request.