This is an administrative penalty action pursuant to Section 312 of EPCRA issued to Rockwell Collins. The company self-disclosed the violations under the EPA Audit Policy. The violations involve failure to provide chemical hazard and inventory information to the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC) and the fire department with jurisdiction as required under Section 312 of EPCRA for the reporting years 2007 thru 2009. Under the EPA's Audit Policy, if the facility has met all nine qualifying criteria, only the economic benefit portion of the penalty may be considered. The Complaint/Consent Agreement establishes that the economic benefit realized by the company as a result of the noncompliance was minimal and that the Respondent has qualified for mitigation of 100% of the gravity portion of the penalty. The penalty would have been approximately $11,860 had the violation been discovered by EPA prior to the self-disclosure under the Policy.