FAILURE TO SUBMIT HAZARDOUS INVENTORY REPORTS TO THE LOCAL EMERGENCY PLANNING COMMITTEE RELIEF SOUGHT: AUD1 AND AUD2 SETTLEMENT FOR ZERO PENALTY UNDER EPA'S AUDIT POLICY. RESPONDENT VOLUNTARILY SELF-DISCLOSED EPCRA SECTION 312 VIOLATIONS AND DEMONSTRATED THAT IT MEETS THE CRITERIA IN THE AUDIT POLICY THAT QUALIFIES IT FOR ZERO GRAVITY BASED PENALTY. ECONOMIC BENEFIT 3WAS DETERMINED TO BE INSIGNIFICANT.