RESPONDENT INITIATED A 7 MONTH SELF-AUDIT OF ALL ITS DOMESTI C AIRPORT FACILITIES, REQUESTED THE APPLICATION OF EPA'S SEL F-DISCLOSURE POLICY, & REPORTED THAT 5 AIRPORTS MISFU ELED 24 AIRPORT GROUND SUPPORT VEHICLES (WHICH MAY BE CLASS IFIED AS MOTOR VEHICLES) WITH HI SULFUR FUEL . PER EPA'S SE LF-DISCLOSURE POLICY, THE GRAVITY COMPONENT IS FULLY MITIGAT ED AND ANY ECONOMIC BENEFIT (EB) IS RECOVERED. EB CALCULATI ON: THE CONVENIENCE OF USING JET FUEL A, PLUS THE COST DIFFE RENCE BETWEEN JET FUEL A AND LOW SULFUR FUEL ($0.028). GALLO NS OF FUEL USED: GALLON OF FUEL PER FILL-UP (20 GALLONS), WI TH AN ASSIGNED VALUE OF $10 PER TRIP TO FUEL = > $500,000 ( ?1,000,000 GALS. O 20 GALS. ? X $10), AND NOT REFLECTIVE OF THE ACTUAL ECONOMIC BENEFIT. THE AVERAGE PENALTY PAID FO R THIS TYPE OF VIOLATION WAS $1,770 PER MOTOR VEHICLE. RESP ONDENT ASSERTED CONSIDERABLE LOST REVENUE AFTER THE SEPTEMBE R 11TH EVENTS AND ACQUIRING CONSIDERABLE SECURITY EXPENSES.