1. VOLUNTARY DISCLOSURE PURSUANT TO THE EPA'S POLICY GUID- ANCE, INCENTIVES FOR SELF-POLICING: DISCOVERY, DISCLO- SURE, CORRECTION AND PREVENTION OF VIOLATION. 2. CITY OF EL PASO TWO CIVIC CENTER PLAZA EL PASO, EL PASO COUNTY, TEXAS 79901-1196 3. RESPONDENT, UNDER THE SELF-POLICING POLICY, DISCLOSED VIOLATIONS OF SECTION 311 OF THE CWA BY A) NO SPILL PREVENTION, CONTAINMENT AND COUNTERMEASURES PLAN FOR THE FACILITIES, AND B) INADEQUATE CONTINGENCY PLAN; VIOLA- TIONS OF SECTION 301 OF THE CWA BY: A) DISCHARGING POLLU- TANTS THAT EXCEEDED PERMITTED EFFLUENT LIMITATIONS, AND B) FAILURE TO USE BEST MANAGEMENT PRACTICES AT THE FACIL- ITIES; VIOLATION OF SECTION 9006 OF RCRA BY A) FAILURE TO REPAIR A LEAKING TANK; VIOLATIONS OF SECTION 3005 OF RCRA BY A) INADEQUATE EMPLOYEE TRAINING, B) NO USABLE 24-HOUR EMERGENCY NUMBER ON SHIPPING DOCUMENT, C) FAILING TO KEEP RECORDS OF ALL HAZARDOUS WASTE AND INDUSTRIAL SOLID WASTE ACTIVITIES REGARDING THE QUANTITIES GENERATED, STORED, PROCESSED, AND DISPOSED OF ON-SITE OR SHIPPED OFF-SITE FOR STORAGE, PROCESSING, OR DISPOSAL, D) FAILING TO RE- TAIN COPIES OF MANIFESTS FOR AT LEAST 3 YEARS, E) FAILING TO MAKE HAZARDOUS WASTE DETERMINATIONS, F) FAILING TO RE- TAIN ANNUAL AND EXCEPTION REPORTS AT LEAST 3 YEARS, G) NO NOTIFICATION OF HAZARDOUS WASTE A