On February 24, 2010 and December 21, 2010, the Respondent self-disclosed possible violations under the Audit Policy for Clean Water Act (CWA). The facility discharged from two school sewage treatment plants with an expired permit and failure to maintain accurate flow meters on the discharges from thirteen school sewage treatment plants. 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 February 24, 2010 Audit Policy request.