The difference between a NOD and NON, is that a NOD is a nonpenalty resolution to a voluntary disclosure that has met all nine conditions of the Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations (“Audit Policy”). It is simply a letter sent to the party that self-disclosed, informing the party that EPA received the self-disclosure information and chooses not to pursue enforcement for the violation at this time. A NON is a nonpenalty, informal enforcement response to a non significant violation. The guidelines for using a NON to address violations are usually described in the program-specific enforcement response policy or penalty policy.
Audit Policy Link: