FAILURE TO FILE FORM RS UNDER SECTION 313 OF EPCRA. FAILURE TO FILE TRI REPORT FOR NITRATE COMPOUNDS IN 1995 AND 1996. U.S. EPA FILED THE COMPLAINT IN THIS MATTER ON MARCH 16, 2000, ALLEGING VIOLATIONS OF SECTION 313 OF EPCRA AND THE REGULATION AT 40 C.F.R. PART 372. SPECIFICALLY, THE COM- PLAINT ALLEGED IN TWO COUNTS THAT RESPONDENT HAS FAILED TO SUBMIT TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORMS COVERING CALENDAR YEARS 1995 AND 1996 FOR NITRATE COMPOUNDS, A TOXIC CHEMICAL THAT WAS MANUFACTURED DURING CALENDAR YEARS 1995 AND 1996 AT RESPONDENT'S FACILITY IN QUANTITIES EXCEEDING THE ESTABLISHED REPORTING THRESHOLD. THE COM- PLAINT PROPOSED A CIVIL PENALTY OF $42,000. FOLLOWING SETTLEMENT DISCUSSIONS, THE PARTIES REACHED A FINAL SETTLE- MENT OF THIS MATTER. UNDER THE TERMS OF SETTLEMENT, SHELDAHL PAID $5,000 IN CIVIL PENALTIES WITHIN 30 DAYS OF THE DATE THE CAFO IS FILED WITH THE REGIONAL HEARING CLERK.