RESPONDENT FAILED TO COMPLY WITH EPCRA 313 GOVERNING THE SUB MISSION OF TOXIC CHEMICAL RELEASE INVENTORIES BY OWNERS AND OPERATORS OF A FACILITY THAT HAS 10 OR MORE FULL-TIME EMPLOYEES AND IS COVERED BY A CERTAIN STANDARD INDUSTRIAL CLASSIFICATION CODE. THIS CASE IS PART OF THE NATIONAL EMERGENCY PLANNING AND COMMUNITY RIGHT TO KNOW ACT STATE OR FEDERAL NON-REPORTER ENFORCEMENT INITIATIVE. RESPONDENT ENTERED INTO AN AGREEMENT UNDER THIS INITIATIVE.