SECTION 313(A) & (B) OF EPCRA REQUIRES THAT OWNER OR OPERAT- OR OF A FACILITY WHICH HAVE 10 OR MORE FULL-TIME EMPLOYEES AND A SIC CODE BETWEEN 20 AND 39, AND WHICH MANUFACTURES, IMPORTS, PROCESSED, OR OTHERWISE USED A TOXIC CHEMICAL IDENTIFIED AT SECTION 313(C) OF EPCRA IN AMOUNTS THAT EX- CEED THE THRESHOLD FOR REPORTING, AS SET FORTH IN SECTION 313(F) OF EPCRA, MUST COMPLETE AND SUBMIT TO THE ADMINISTRA- TOR OF U.S.EPA AND THE STATE NO LATER THAN JULY 1, 1988, AND JULY 1 THEREAFTER, A CHEMICAL RELEASE FROM PUBLISHED PURSUANT TO SECTION 313(G) OF EPCRA, FOR EACH CHEMICAL COVERED DURING THE REPORTING CALENDAR YEAR. - RESPONDENT WAS REQUIRED TO SUDMIT A CHEMICAL RELEASE FORM AND FAILED TO SUBMIT TO U.S.EPA AND THE STATE ON JULY 1, 1988.