This is an Administrative Penalty action pursuant to EPCRA 313 issued to Kelly-Moore Paint Company, Inc. The violation involves failure to file timely Toxic Chemical Release Inventory Forms required under Section 313 for zinc compounds and certain glycol ethers in 2004 and 2005. The Respondent self-disclosed this omission on 7/15/2008. Pursuant to the EPA Audit Policy the Respondent did not meet the criteria for 100% mitigation of the penalty (calculated at 108,800). Accordingly, the CAFO establishes a penalty of $17,136 and a SEP in the amount of $68,544.