This is a resolution of a voluntary disclosure by means of an administrative penalty action issued to High Desert Power Project, LLC (Respondent) pursuant to the EPCRA. The violation involves failure to timely submit annual chemical inventory formes, for its Victorville, California, electric power generating plant that uses lead acid batteries containing sulfuric acid and lead in amount over the threshold planning quantity. During an environmental audit of its operations, Respondent discovered a violation of EPCRA Section 312, and promptly disclosed its violation to EPA. This enforcement action was based on the voluntary self-disclosure by Respondent, and resolved by a CA/FO initiating and resolving the violations pursuant to 40 CFR Sections 22.13 and 22.18. Application of the Audit Policy resulted in 100% penalty mitigation (zero dollars).