On January 25, 2011, the Respondent self-disclosed possible violations under the Audit Policy at its Watertown, NY facility for potential violations with the Clean Air Act (CAA). The facility failed to notify regarding the state of boiler construction and startup, and to include related information in the semi-annual report. Also, they failed to maintain records of fuel sulfur content and fuel usage. 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. The Respondent corrected the violations that were disclosed on the January 25, 2011 Audit Policy request.