ON OR ABOUT 08/11/92, AN AUTHORIZED EPA EMPLOYEE INSPECTED RESPONDENTS FACILITY. THE PURPOSE OF THE INSPECTION WAS TO DETERMINE RESPONDENTS COMPLIANCE WITH EPCRA REPORTING REQUIREMENTS. AS A RESULT OF THE INSPECTION AND SUBSEQUENT COMMUNICATIONS BETWEEN THE INSPECTOR AND RESPONDENT, THE COMPLAINANT HAS DETERMINED THE FOLLOWING: DURING EACH OF THE 1988, 1989, AND 1990 CALENDAR YEARS; IN EXCESS OF 10,000 POUNDS OF PHOSPHORIC ACID WAS USED. RESPONDENT FAILED TO SUBMIT A FORM R TO THE STATE PRIOR TO JULY 1 OF THESE YEARS. ADDITIONALLY, IN EXCESS OF NITRIC ACID WAS ALSO USED DURING THESE YEARS WITH NO ACCOMPANYING FORM R. THE PROPOSED CIVIL PENALTY FOR THIS COMPLAINT IS $102,000. 07/19/93: FINAL ORDER ISSUED, EPA AGRESS TO REDUCED PENALTY OF $71,400.