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independent of government or third party plaintiff; (5) correction and remediation; (6) <br /> prevention of recurrence; (7)no repeat violations; (8) other violations excluded; and(9) <br /> cooperation. <br /> 27. Regulated entities deemed by EPA to have satisfied the nine conditions in the Audit <br /> Policy will not face any gravity-based civil penalties. If the regulated entity meets all but <br /> the first condition(Systematic Discovery),EPA will reduce the gravity-based penalties <br /> by 75%. EPA reserves the right to collect any economic benefit realized as a result of the <br /> violation disclosed. <br /> 28. EPA has concluded that Respondent has, as described herein,satisfied the nine conditions <br /> outlined in the Audit Policy and therefore will not face gravity-based civil penalties. <br /> 29. Systematic Discovery of the Violation through an Environmental Audit or a Compliance <br /> Management System. Respondent discovered the violations as the result of an <br /> environmental compliance management system. Periodic updates of regulations that <br /> affect the Facility operations are a part of the compliance management system in place at <br /> the Facility. Respondent discovered the violation on November 29, 2007. While <br /> evaluating the data element updates required by the California Accidental Release <br /> Prevention(CaIARP)program,Respondent discovered that the previous management had <br /> failed to submit the RMP to US EPA in order to meet the reporting requirements of the <br /> CAA 112(r)(7). <br /> 30, Voluntary Discovery. Respondent's discovery of the violations was voluntary and did <br /> not result from any legally mandated monitoring or sampling requirement prescribed by <br /> statute,regulation, permit,judicial or administrative order, or consent agreement. <br /> 6 <br /> CA/FO Provena Foods,dba Swiss American Sausage Co.,Lathrop,CA <br />