Respondent submitted under the Audit Policy a disclosure for two of its facilities; GE Rotterdam Tooling Center, and the North Americas Tool Center. Both sites for failure to report under EPCRA Tier II reporting (EPCRA 312) for storage of sulfuric acid. Respondent fixed all issues. EPA determined the facilities meet the conditions of the Audit Policy for 100% elimination of the total gravity-based penalties which could have been otherwise assessed for the Emergency Planning and Community Right-to-Know Act (EPCRA) violation outlined in the disclosure.