If a company submits a self-disclosure to EPA but subsequently withdraws the disclosure because there are no violations, and EPA agrees that no violations occurred, then the disclosure should be considered withdrawn. Enter "withdrawn" as the "Resolution" on the voluntary disclosure basic info screen in ICIS. Enter "No violations occured" in the "Rational for not applying the Disclosure Policy" field. Do not enter a NOD on the enforcement action screens. The withdrawn disclosure will be counted toward the EOY totals for facilities and entities resolved. It will not be counted in the totals for voluntary disclosure resolutions that serve as the denominator for percentage with Direct Environmental Benefits or EMP because it is not appropriate.
A Notice of Determination (NOD) is a specific enforcement action resolution type for a Voluntary Disclosure. The NOD is used when an entity meets all nine conditions of the Policy and no penalty is appropriate (i.e., EBN is insignificant).