Momentive Specialty Chemicals, Inc. has five facilities in Baytown, Tx, Hope, Ar, Okla. City, OK, Cleburne,Tx, and Alexandria, LA that disclosed violation of EPCRA 313 to U.S. EPA. After reviewing the Audit Poiicy Checklist they submitted, 100% of the gravity base penalty was mitigated. Economic benefit was deemed insignificant.