RESPONDENT'S FAILURE TO TIMELY FILE A COMPLETE FORM R OR FORM A WITH EPA AND THE COMMONWEALTH OF PENNSYLVANIA FOR THE TOXIC CHEMICAL CATEGORY, NITRATE COMPOUNDS, MANUFACTURED AT THE FACILITY DURING THE CALENDARS YEARS 2012, 2013, AND 2014 CONSTITUTES THREE VIOLATIONS OF SECTION 313 OF EPCRA, 42 U.S.C. SECTION 11023 AND 40 C.F.R. SECTION 372.30.