This is a self-disclosure case under the Audit Policy. Pursuant to 40 CFR Part 60 (SubPart VVV), a Consent Agreement was filed regarding Koch Membrane Systems, San Diego, CA. The underlying violation involves record keeping and reporting. Koch Membrane Systems showed they were in compliance and had been in compliance by doing several material balance tests around Casting machine E. The economic benefit portion of the penalty policy calculation was less than $5,000. The gravity portion was entirely waived. No penalty was assessed.