Through information provided on December 20, 2011 and February 1, 2012, Solutia Inc. self-disclosed its potential noncompliance with 40 C.F.R. Part 82. EPA has determined that the violations in the self-disclosure submitted by Solutia do not meet all nine criteria for penalty reduction pursuant to the Self-Disclosure Policy. Condition 2 of EPAÂs Audit Policy requires that disclosed violations should be discovered voluntarily. Violations discovered by a Title V permit holder that should have been discovered through a legally mandated monitoring requirement prescribed by the Title V regulations do not meet the condition for voluntary discovery.