Respondent's failure to submit to EPA and the Commonwealth Pennsylvaniam by July 1, 2013, completed Form Rs or Form As to report its processing of n-Butyl Alcohol and Ethylene Glycol at the Facility during the calendar year 2012, constitutes two separate violations of Section 313 of EPCRA for which Respondent is liable for civil a penalty pursuant to Section 325(c) EPCRA.