On December 22, 2010, the Respondent self-disclosed possible violations at its Bernzomatic facility, located in Medina, NY, under the Audit Policy for possible violations with the Clean Air Act (CAA) and Emergency Planning & Community Right to Know Act (EPCRA). The facility failed to prepare a Risk Management Plan (CAA) and failed to submit 2009 inventory reports for lead, sulfuric acid and petroleum products (EPCRA). Pursuant to the Audit Policy and based on information provided, EPA has determined that the facility meets the conditions of the Audit Policy for 100% elimination of the total gravity-based penalties. The Respondent corrected the violations that were disclosed on the December 22, 2010 Audit Policy request.