This is an administrative penalty action pursuant to Section 312 of EPCRA issued to United Comb and Novelty Corporation for their United Solutions facility located in Gilbert, AZ. The company self-disclosed the violations under the EPA Audit Policy. The violations involve failure to provide an annual chemical inventory for reporting year 2009 to the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC), and the Gilbert Fire Department as required under Section 312 of EPCRA. 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 $32,000 had the violation been discovered by EPA prior to the self-disclosure under the Policy.