Elementis Chromium, Inc. (“Elementis”) appeals an Initial Decision the Chief Administrative Law Judge (“ALJ”) issued assessing a $2,571,800 administrative civil penalty against it for violating section 8(e) of the Toxic Substances Control Act (“TSCA”), 15 U.S.C. § 2607(e). The ALJ concluded that Elementis failed to report to the Environmental Protection Agency information contained in an occupational epidemiology study on hexavalent chromium.