On June 17, 2011 Respondent disclosed potential violations under Resource Conservation Recovery Act (RCRA) for failure to manage hazardous waste (hw) as a large quantity generator; pharmaceutical waste as hw; hw manifest; and failure to maintain training records of handlers of hw. In addition RCRA Underground Storage Tank failure to maintain record of release detection. Under the Clean Water Act (CWA) Spill Prevention Control Countermeasure (SPCC) the Respondent failed to maintain secondary containment and records of discharges, inspections and training. 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. Respondent corrected the violations that were disclosed on the June 17, 2011 Audit Policy request.