RESPONDENT FAILED TO FILE FORMS R FOR FIVE CHEMICALS LIS- TED UNDER 40 CFR 372.65 BY THE JULY 1, 1988, REPORTING DEAD- LINE FOR THE 1987 CALENDAR YEAR. FAILURE TO FILE THE FORMS R BY THE DEADLINE SUBJECTS THE RESPONDENT TO CIVIL PENALTY LIABILITY FOR EACH CHEMICAL. RESPONDENT FILED FORMS R FOR THE CHEMICALS LISTED IN THE COMPLAINT, ONLY AFTER USEPA IN- SPECTORS HAD NOTIFIED THE RESPONDENT OF THEIR INTENTION TO INSPECT. THUS THE RESPONDENT'S DELAYED FILING IN CHARACTERI ZED AS A NON-FILING IAW THE AGENCY'S ENFORCEMENT RESPONSE POLICY. TOTAL AMOUNT OF THE PROPOSED PENALTY IS $51,000.