THIS IS A SELF-DISCLOSURE CASE INVOLVING VIOLATIONS OF CERCLA 103, EPCRA 304, AND EPCRA 313. THE COMPLAINT WAS ISSUED ON SEPTEMBER 29, 1993, AND ON THE SAME DAY, SARA LEE AND THE AGENCY SIGNED A CONSENT AGREEMENT SETTLING THE CASE FOR A PENALTY OF $118,830. THE CACO WAS TRANSMITTED TO THE 10TH FLOOR FOR CONVEYANCE TO THE EAB ON OCTOBER 21ST. THE CACO INCLUDES A CORPORATE-WIDE AUDIT FOR COMPLIANCE WITH CERCLA SECTION 103 AND ALL OF EPCRA.