ON MARCH 31, 1995, REGION V FILED AN ADMINISTRATIVE COMPLAINT AGAINST RESPONDENT ALLEGING IN THREE COUNTS THAT RESPONDENT VIOLATED SECTION 313 OF EPCRA, 42 U.S.C. 11023, AND 40 C.F.R. PART 372 BY FAILING TO TIMELY SUBMIT TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORMS ( FORMS R ) FOR COPPER, A TOXIC CHEMICAL THAT WAS PROCESSED DURING CALENDAR YEARS 1989, 1990 AND 1991 AT RESPONDENT'S FACILITY LOCATED AT N114W19250 CLINTON DRIVE, GERMANTOWN, WISCONSIN 53022, IN QUANTITIES ABOVE THE ESTABLISHED THRESHOLD FOR REPORTING. THE COMPLAINT PROPOSED A TOTAL CIVIL PENALTY OF $55,986. RESPONDENT DID NOT FILE AN ANSWER TO THE COMPLAINT OR REQUEST A HEARING.