1. SECTION 325(C) OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT OF 1986 ( EPCRTKA ), 42 U.S.C. SEC. 11045(C). 2. HELDENFELS BROTHERS INC. 1401 NAVIGATION CORPUS CHRISTI, TEXAS 78469 3. RESPONDENT WAS IN VIOLATION OF THE REPORTING REQUIREMENTS OF EPCRTKA SEC. 312(A) BY FAILING TO SUBMIT BY MAR. 1, A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM WITH RESPECT TO THE HAZARDOUS CHEMICAL LOCATED AT THE FACILITY TO THE LOCAL, COUNTY AND STATE AGENCIES. 4. RELIEF SOUGHT PURSUANT TO SECTION 325(C) OF EPCRTKA, EPA PROPOSES A PENALTY OF $6,600.00.