DURING AN INSPECTION CONDUCTED DURING JULY 1995, EPA ASKED THE RESPONDENT THE BASIS OF THE ESTIMATE AND THE CALCULA- TIONS FOR THE AUGUST 1992 FORM R FILING. RESPONDENT RE- PLIED THAT HE HAD NO IDEA OF HOW THE NUMBERS WERE ARRIVED AT. THIS OCCURED 3 TIMES FOR VARIOUS CHEMICALS. RESPONDENT ALSO FAILED TO SUBMIT FORM R FOR CALENDAR YEARS 1992 AND 1993. A FEDERAL PENALTY OF $73,000 WAS PROPOSED.