B.L. DOWNEY WAS REQUIRED TO SUBMIT TO THE ADMINISTRATOR OF USEPA AND TO THE STATE OF ILLINOIS ON OR BEFORE JULY 1, 1988 A FORM R FOR TWO CHEMICALS IT OTHERWISE USED . RESPONDENT FAILED TO SUBMIT 2 FORM R FOR THE CHEMICALS IT OTHERWISE USED ON OR BEFORE JULY 7, 1988, WHICH CONSTITUTES A VIOLA- TION OF EPCRA SECTION 313.