1. SECTION 325(C) OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT OF 1986 ( EPCRA ), 42 U.S.C. SECTION 11045(C). 2. MID-SOUTH CASTINGS, AN ARKANSAS COMPANY 4721 SOUTH ZERO STREET FORT SMITH, SEBASTIAN COUNTY, ARKANSAS 72903 3. RESPONDENT WAS IN VIOLATION OF THE REPORTING REQUIREMENTS OF SECTION 313(A) OF EPCRA BY: 1) FAILURE TO REPORT IN A TIMELY MANNER FOR CALENDAR YEAR 1998 (NICKEL) AND 2) FAILURE TO REPORT IN A TIMELY MANNER FOR CALENDAR YEAR 1998 (COPPER). 4. RELIEF SOUGHT PURSUANT TO SECTION 325(C) OF EPCRA, EPA PROPOSED A CIVIL PENALTY OF 5,672 FOR THE VIOLATIONS CITED.