Audit Policy Case - On Spetember 26,2003, EPA issued a Notice of Violation based on a self-disclosure provided by Rohm and Haas Comapny, Philadelphia Plant for violations of Section 313 of EPCRA. In letters to EPA dated April 4, 2003, May 23, 2003, and in subsequent responses to EPA Rohm and Haas disclosed that they had under reported the amount of chemicals to be released offsite on the Toxic Chemical Relese Inventory Form. The total gravity-based civil penalty for these violations would be 44,000.00, However, Rohm and Haas satisfied all of the conditions of EPA's Self-Disclosure Policy and therefore EPA waived the gravity-based civil penalty for the disclosed violations