'This is an Administrative Penalty action pursuant to Section 325(c) of Title II of the Superfund Amndments and Reauthorization Act (EPCRA) issued in resolution of a Self-Audit/Self-Disclosure received from AXT, Inc. The violation involves a failure to submit timely a Form R reports for methanol otherwise used at the facility in 1997 and 1998, and for nitric acid otherwise used at the facility in 1998. Because the Respondent''s self-disclosure of these violations meets the criteria of EPA''s Audit Policy, the penalty that would have been due has been reduced to zero dollars (100% mitigation).'