This is a zero-penalty APO pursuant to ECPRA Sections 311 and 312 issued to Texas Hill Diamante Cooling, LLC and relating to a self-audit under the Audit Policy. The violations involve failure to provide MSDSs to the SERC and LEPC as required under EPCRA Section 311 and failure to provide annual chemical inventory information for reporting years 2001 and 2002 to the SERC, LEPC and Fire Department. These violations were self-disclosed and all criteria under the audit policy were met for 100% mitigation of the gravity portion of the penalty. Economic benefit was calculated as approximately $904. Total penalty assessed = $0.