This is an administrative penalty action pursuant to Sections 311 and 312 of EPCRA issued to Kaiser Aluminum Alexco, LLC. The company self-disclosed the violations under the EPA Small Business Policy and Audit Policy. The violations involve failure to provide annual chemical inventories to the SERC, LEPC and the fire department with jurisdiction for the reporting year 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 $37,500 had the violation been discovered by EPA prior to the self-disclosure under the Policy.