On April 20, 2011, the Respondent, in Bronx, New York City, disclosed potential violations for RCRA, CWA and CAA. The facility's Title V Clean Air Act permit precludes air program violations from Audit Policy eligibility, therefore, the CFC violation for failure to maintain refrigerant leak-rate calculations are not eligible and has been referred to EPAÂs air program. However, the hazardous waste (i.e.RCRA) and spill prevention countermeasure plan (i.e.CWA) violations are eligible. For RCRA, failure to do the following: limit hazardous waste (hw) accumulation time to 180 days; document hw training prior 2010; ship hw pharmaceutical waste to a facility licensed to receive it; date boxes of universal waste bulbs and keep them closed. For CWA, failure to do the following: have effective oil storage tank overfill protection; to inspect all oil storage containers. Pursuant to the Audit Policy and based on information provided, EPA has determined that the Respondent meets the conditions of the Audit Policy for 100% elimination of the total gravity-based penalties disclosed for RCRA and CWA. The facility corrected the RCRA and CWA violations that were disclosed on April 20, 2011.