An E-disclosure under the Audit Policy was submitted to the United States Environmental Protection on September 12, 2011. It was disclosed the facility failed to file TRI Form R reports for nitric acid for calendar years 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 reports were submitted to the EPA on September 9, 2011.