This is an Administrative Penalty action pursuant to EPCRA 313 issued to Hightower Plating & Manufacturing (Kurt Koch, President). The violation involves failure to timely file Form Rs for chromium and manganese in the years 2002-2004, and for cobalt in 2002. The respondent disclosed this information to the EPA on 11/16/2006. Pursuant to the EPA Audit Policy, the respondent met all criteria for 100% mitigation. Accordingly the penalty (calculated at $42,300) will be mitigated to zero ($0).