The Respondent submitted late Toxic Release Inventory (TRI) Form R reports for manganese compounds and cobalt compounds for calendar year 2012. The reports were due July 1, 2013. They were submitted to the United States Environmental Protection Agency on December 2, 2013. A Consent Agreement and Final Order was issued to the company December 19, 2013 in which the company agreed to pay a $6,481 penalty pursuant to the Emergency Planning and Community Right-to-Know Act of 1986 and the Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties. 42 U.S.C. § 11001 et seq. and 40 C.F.R. § 22.13(b).