DURING 1987 AND 1988 RESPONDENT PROCESSED SULFURIC ACID IN QUANTITIES EXCEEDING FEDERALLY REQUIRED THRESHOLD FOR REPORTING AND FAILED TO FILE FORM R FOR EITHER YEAR. DURING 1987 AND 1988, RESPONDENT PROCESSED HYDORCHLORIC ACID IN QUANTITIES EXCEEDING THE FEDERALLY REQUIRED THRESHOULD FOR REPORTING AND FAILED TO FILE A FORM FOR EITHER YEAR.