A show cause letter of inquiry was sent to the Respondent on August 23, 2011 to initiate an enforcement action. The Respondent submitted late Toxic Release Inventory (TRI) Form R reports for di(2-ethylhexyl)phthalate, toluene, and zinc compounds for calendar year 2010. The reports were due July 1, 2011. The reports were submitted to the EPA on July 18, 2011. Each failure to submit a Form R report, in a timely manner, constitutes a violation of Section 313 of EPCRA, 42 U.S.C. §11023, and of 40 C.F.R. §372.30.