FAILURE TO FILE FORM R. PROGRAM WORKING ON HOW TO PRESENT ISSUE TO RESPONDENT. THE FACILITY SELF-DISCLOSED THE EPCRA 312 VIOLATIONS TO U.S. EPA. THE SELF-SISCLOSURE POLICY WAS APPLIED TO MITIGATE THE PROPOSED PENALTY. UNDER THE SELF-DISCLOSURE POLICY, IF A FACILITY MEETS ALL THE CONDITIONS DESCRIBED IN THE POLICY, THE PROPOSED GRAVITY-BASED PENALTY WILL BE REDUCED BY 75%. COUSINS FOODS, LTD MET ALL THE CONDITIONS DESCRIBED IN THE POLICY, THEREFORE THE PROPOSED PENALTY TO $1,500 WAS MITIGATED BY 75%, THE FINAL PENALTY WAS $375. APPLIED 75% REDUCTION FROM AUDIT POLICY FOR SETTLEMENT. NO OTHER REQUIREMENTS TO SETTLEMENT BEYOND PAYMENT OF THE PENALTY.