THIS IS AN ADMINISTRATIVE CASE BROUGHT UNDER 313 OF EPCRA, 42 U.S.C. 11023. THE COMPLAINT CONTAINS 34 SEPARATE COUNTS THAT FALL INTO THREE CATEGORIES: (1) FAILURE TO FILE THE FORM R NOTICE, (2) FAILURE TO MAINTAIN RECORDS REQUIRED BY EPCRA, AND (3) REPORTING INCORRECT AMOUNTS OF CERTAIN CHEMICALS USED, PROCESSED OR MANUFACTURED AT THE FACILITY. THE 34 SEPARATES COUNTS ARISE BECAUSE SIMILAR ALLEGATIONS APPLY TO SEVERAL DIFFERENT CHEMICALS. A CIVIL PENALTY HAS BEEN CALCULATED FOR EACH OF THE 34 COUNTS AND THE TOTAL CIVIL PENALTY SOUGHT IS $498,000.