THIS CASE INVOLVES TWO VIOLATIONS OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT ( EPCRA ). SPECIFICALLY, THE RESPONDENT FAILED, FOR CALENDAR YEARS 1987 AND 1988, TO FILE THE REQUISITE FORM R TO REPORT ITS EMISSIONS OF 1,1,1-TRICHOLOROETHANE (METHYL CHLOROFORM). THE FORM R FOR 1987 WAS 671 DAYS LATE WHILE THE ONE FOR 1988 WAS 306 DAYS LATE. THIS CASE INVOLVES VIOLATIONS OF SECTION 313 OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT (EPCRA). SPECIFICALLY, RESPONDENT FAILED TO FILE ITS TOXIC CHEMICAL RELEASE INCENTORY FORMS (INDIVIDUALLY REFERRED TO AS A FORM R ) AS REQUIRED BY SECTION 313 OF EPCRA FOR CALENDAR YEARS 1987 AND 1988 FOR ITS USE OF 1,1,1-TRICHLOROETHANE AT ITS LAKE ELECTRIC MOTORS FACILITY IN RACINE, WISCONSIN.