An E-disclosure under the Audit Policy was submitted to the EPA on September 1, 2011. Hazard Evaluations, Inc. completed an audit of the facility to determine compliance with EPCRA on August 22, 2011. The consulting firm determined that the facility had failed to file TRI Form R reports for nitric acid for calendar years 2005, 2006, 2007, 2008, 2009 and 2010. The facility did not exceed the 25,000 pound threshold for manufacturing nitrate compounds and, therefore, was not required to file Form R reports for nitrate compounds. The required Form R reports were filed on August 31, 2011.