1. SECTION 325 OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT ( EPCRA ), 42 U.S.C. SECTION 11045. 2. INTERCONTINENTAL MFG., A TEXAS CORPORATION 1200 NORTH GLENBROOK DRIVE GARLAND, DALLAS COUNTY, TEXAS 75046-1148 3. RESPONDENT WAS IN VIOLATION OF THE REPORTING REQUIREMENTS OF SECTION 313 OF EPCRA BY FAILING TO TIMELY SUBMIT A COMPLETE AND ACCURATE FORM R OR FORM A FOR CALENDAR YEARS 1995, AND 1998, FOR NITRATE COMPOUNDS. 4. RELIEF SOUGHT PURSUANT TO SECTION 325 OF EPCRA, EPA PRO- POSED A CIVIL PENALTY OF $5,000 FOR THE VIOLATIONS AL- LEGED IN THE CAFO.