This is an Administrative Penalty action pursuant to EPCRA Section 313 regarding a self-disclosed violation by Three Bond International for failure to submit timely Form Rs for Di (2-ethylhexyl) phthalate or DEHP for calendar years 2001 through 2003 as required by Section 313 regulations. Respondent self disclosed its omissions and under the EPA Audit Policy, met all criteria necessary to warrant a 100% penalty mitigation. Therefore, the proposed penalty of $14,169 is mitigated to zero penalty.