Respondent submitted a late Toxic Release Inventory (TRI) Form R report for nitric acid for calendar year 2012. The report was due July 1, 2013. It was submitted to EPA on June 17, 2014.. 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. The final penalty was $19,974.