1. VOLUNTARY DISCLOSURE PURSUANT TO THE EPA'S POLICY GUID- ANCE, INCENTIVES FOR SELF-POLICING: DISCOVERY, DISCLOS- URE, CORRECTION AND PREVENTION OF VIOLATION. 2. WITCO CORPORATION, A TEXAS CORPORATION 15200 ALMEDA ROAD HOUSTON, HARRIS COUNTY, TEXAS 77053-5296 3. RESPONDENT, UNDER THE SELF-POLICING POLICY, DISCLOSED A POSSIBLE VIOLATION OF THE REPORTING REQUIREMENTS OF CER- CLA 103(A) AND EPCRA 313. AFTER AN INTERNAL AUDIT, THE RESPONDENT DISCOVERED THAT RELEASES OF METHYL CHLORIDE MAY HAVE OCCURRED FROM CERTAIN INTERMITTENLY-CONDUCT BATCH CHEMICAL PROCESS OPERATIONS. 4. RELIEF SOUGHT PURSUANT TO THE SELF-POLICING POLICY, EPA WILL ISSUE A FINAL DETERMINATION, AFTER REVIEW OF THE RESPONDENT DISCOVERY OF THE VIOLATION, PROMPT DISCLOSURE, CORRECTION OF THE VIOLATION AND PREVENTION OF RECURRENCE, ON WHETHER TO SEEK GRAVITY-BASED PENALTIES OR NOT.