1. SECTION 325 OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT ( EPCRA ), 42 U.S.C. SECTION 11045. 2. EAST TEXAS ENGRAVING, A TEXAS CORPORATION 116 SOUTH BECKHAM TYLER, SMITH COUNTY, TEXAS 75702 3. RESPONDENT WAS IN VIOLATING OF THE REPORTING REQUIREMENTS OF SECTION 313 OF EPCRA BY FAILING TO TIMELY SUBMIT A COMPLETE AND ACCURATE FORM R AND FORM A FOR CALENDAR YEARS 1995, 1996, 1997, AND 1998, FOR NITRATE COMPOUNDS. 4. RELIEF SOUGHT PURSUANT TO SECTION 325 OF EPCRA, EPA PRO- POSED A CIVIL PENALTY OF $1,000 FOR THE VIOLATIONS CITED.