This is an Administrative Penalty action pursuant to EPCRA 313 issued to Hydril Company dba Bakersfield Manufacturing Plant. The violation involves failure to file timely Toxic Chemical Release Inventory Forms required under Section 313 for lead in 2007, and for chromium, manganese, and nickel in 2007 and 2008. The Respondent self-disclosed these omissions on 7/20/2010. Pursuant to the EPA Audit Policy the Respondent met the criteria for 100% mitigation of the penalty (calculated at $197,300). Accordingly, the CAFO establishes a penalty of zero dollars ($0).