THE COMPLAINT CITES 19 COUNTS FOR FAILURE TO SUBMIT TOXIC CHEMICAL RELEASE FORMS (FORM RS) AS REQUIRED BY SECTION 313 OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT AND 40 C.F.R. SEC. 372.30 FOR 8 TOXIC CHEMICALS PROCESSED OR OTHERWISE USED BY IMCO AT ITS GARLAND, TX. FACILITY. THE PROPOSED CIVIL PENALTY IS $318,284. IMCO IS IN THE BUSINESS OF MANUFACTURING HELICOPTER PARTS AND BOMB AND ARTILLERY CASINGS. ITS GARLAND, TX. FACILITY PROCESSES OR OTHERWISE USES NUMEROUS TOXIC CHEMICALS. DURING CALENDAR YEARS 1990 - 1992, THE COMPANY PROCESSED OROTHERWIS E USED TOXIC CHEMICALS IN QUANTITIES EXCEEDING THE APPLIC- ABLE REPORTING THRESHOLDS. THE FACILITY WAS INSPECTED BY EPA ON JUL. 8, 1993. THE COMPANY HAD NOT FILED FORM RS FOR 1990, 1991, AND 1992. ADDRESS: 1200 NORTH GLENBROOK DRIVE GARLAND, TX. 75040