PORT ALLEN PLANT (Criterion Catalysts & Technologies L.P.) disclosed violation of EPCRA 313 to U.S. EPA. Port Allen facility disclosed failure to complete and timely submit required reporting forms for 2009 as required by EPCRA 313(a), 42 USC and 11023(a) and 40 CFR and 372.85(b). After reviewing the Audit Policy Checklist that was submitted, 100% of the gravity base penalty was mitigated. Economic benefit was deemed insignificant. NOD issued 11/14/2011 with no penalty.