EPCRA ADMINISTRATIVE CASE EPCRA SECTION 312 INITIATIVE. IMPACT: ON AUGUST 21, 1997, THE REGIONAL ADMINISTRATOR EXEC UTED A CONSENT AGREEMENT AND CONSENT ORDER WHICH WAS FILED O N AUGUST 26 WITH AN EPCRA ADMINISTRATIVE COMPLAINT AGAINST R ESPONDENT, ELGIN DAIRY FOODS INC., OF CHICAGO, ILLINOIS. TH E CONSENT AGREEMENT AND CONSENT ORDER PROVIDES FOR PAYMENT O F $2,000 CIVIL PENALTY BY RESPONDENT FOR VIOLATIONS OF SECTI ON SECTION 312 OF EPCRA, 42 U.S.C. 11022. BACKGROUND: ON JULY 1, 1997, REGION 5 SENT ELGIN DAIRY, INC . A PRE-FILING NOTICE LETTER INCLUDING EPA'S INTENT TO BRING PROCEEDINGS AGAINST ELGIN DAIRY, INC. FOR VIOLATIONS OF SECT ION 312 OF EPCRA, 42 U.S.C. 11022. THIS LETTER OFFERED EL GIN DAIRY, INC. AN OPPORTUNITY TO PARTICIPATE IN A NATIONAL EPCRA SECTION 312 ENFORCEMENT AGREEMENT DIRECTED TOWARD INDU STRIES INCLUDING THOS IN ELGIN DAIRY, INC.'S STANDARD INDUST RIAL CLASSIFICATION. THIS AGREEMENT REQUIRES FACILITIES TO SUBMIT COMPLETE CHEMICAL INVENTORY FORMS AS REQUIRED BY EPCR A. IN EXCHANGE, PARTICIPATING FACILITIES MUST PAY A PENALTY OF $2,000. THIS SIGNED CACO EMBODYING THIS AGREEMENT WAS FI LED TOGETHER WITH A COMPLAINT FOR THE VIOLATIONS ALLEGED. C OUNT I ALLEGES THAT RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM FOR THE 1994 CALENDAR YEAR BY MARCH 1, 1995, TO THE STATE EMERGENCY RESPO NSE COMMISSION, IN VIOLATION OF SECT