1. SECTION 325(C) OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT ( EPCRA ), 42 U.S.C. SEC. 11001 ET SEQ. 2. UNION CARBIDE CORPORATION RIVER ROAD HAHNVILLE, LOUISIANA 70057 SIC CODE: 2819 AND 2822 3. RESPONDENT WAS IN VIOLATION OF SECTION 313(A) OF EPCRA BY FAILING TO SUBMIT A COMPLETE AND CORRECT FORM R TO THE ADMINISTRATOR OF EPA AND THE STATE OF LOUISANA FOR THE TOXIC CHEMICAL SILVER. THE RESPONDENT FAILED TO SUBMIT THE FORMS FOR CALENDAR YEARS 1992 AND 1993. 4. RELIEF SOUGHT PURSUANT TO SECTION 325(C) OF EPCRA, EPA PROPOSES A CIVIL PENALTY OF $42,000, $17,000 FOR COUNT 1, CALENDAR YEAR 1992, AND $25,000 FOR COUNT 2, CALENDAR YEAR 1993.