FAILURE TO FILE TRI REPORTS RESPONDENT, QUEBECOR WORLD (USA), INC., THROUGH ITS EFFINGHAM DIVISION, OTHERWISE USED 26,632 POUNDS OF 1,2, 4-TRIMETHYLBENZENE IN CALENDAR YEAR 1998, AND OTHERWISE USED 29,832 POUNDS OF ETHYLENE GLYCOL IN CALENDAR YEAR 1998, AND FAILED TO SUBMIT TO EPA AND TO THE STATE OF ILLINOIS A FORM R FOR EACH OF THESE CHEMICALS ON OR BEFORE JULY 1, 1999. THEREFORE, RESPONDENT COMMITTED TWO VIOLAT- IONS OF SECTION 313 OF EPCRA. U.S. EPA FILED A COMPLAINT AGAINST QUEBECOR WORLD (USA) ON DECEMBER 28, 2000, AND PROPOSED A PENALTY OF $28,936.