EPA ISSUED A CIVIL COMPLAINT TO HFHC ON MAY 23, 1994 FOR FAILURE TO SUBMIT TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORMS (FORM R) FOR CALENDAR YEARS 1989, 1990 AND 1991 FOR PHOSPHORIC ACID, AS REQUIRED BY SECTION 313 OF EPCRA AND FEDERAL REGULATIONS PROMULGATED TO IMPLEMENT SECTION 313, FOR ITS FACILITY. THE CIVIL PENALTY ASSESED IN THE COMPLAINT FOR THESE VIOLATIONS WAS $51,000.