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. BAY INC. 6101 HOPKINS ROAD CORPUS CHRISTI, NUECES COUNTY, TEXAS 78469 3. RESPONDENT WAS IN VIOLATION OF SECTION 312(A) OF EPCRTKA BY FAILING TO SUBMIT BY MAR. 1, 1995, A COMPLETED EMERG- ENCY AND HAZARDOUS CHEMICAL INVENTORY FORM WITH RESPECT TO THE HAZARDOUS CHEMICAL LOCATED AT THE FACILITY TO THE PROPER LOCAL, COUNTY AND STATE AGENCIES. 4. RELIEF SOUGHT PURSUANT TO SECTION 325(C) OF EPCRTKA, EPA PROPOSES A CIVIL PENALTY OF $6,600.