Beelman Ready Mix disclosed that they violated Clear Air Act Lifetime Operating Permit requirements, by failing to keep production records and emission records on site. BeelmanÂs disclosure of CAA and SPCC violations meet all nine criteria for penalty reduction pursuant to the Self-Disclosure Policy and thus are eligible for a waiver of all civil gravity-based penalties EPA might otherwise seek for these violations. Additionally, due to the insignificant amount of any economic benefit gained as a result of these violations, EPA has determined that it will not attempt to collect such economic benefit. In consideration of these determinations, EPA will not seek any penalties for the CAA and SPCC violations Beelman disclosed in the August 25, 2011, December 6, 2011, and July 11, 2012, letters to EPA.