SEE ALSO PREVIOUS MATTER NUMBER 04-97-0095. (ARCHIVED) COMPLAINT FILED 10/23/97, COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO SUBMIT WRITTEN NOTICE OF THE DATES IT PLANNED TO CONDUCT INITIAL CERTIFICATION TESTS FOR NITROGEN OXIDE CEMS FOR UNITS 1,2,3 OR THE DATES IT PLANNED TO CONDUCT TESTS TO CERTIFY USE OF THE APPENDIX E PROTOCOL FOR UNITS C AND D TO EITHER THE ADMINISTRATOR OR EPA REGION 4. IN VIOLATION OF CAA 40 C.F.R. SECTION 75.20(A) (1), 40 C.F.R. SECTION 75.60(B) AND 40 C.F.R. SECTION 75.61 (A) (1) (I). COUNT II RESPONDENT FAILED TO COMPLETE INITIAL TESTS TO CERTIFY USE OF THE APPENDIX E PROTOCOL ON UNITS C AND D BY THE JANUARY 1, 1996 REGULATORY DEADLINE. IN VIOLATION OF CAA 40 C.F.R. SECTION 75.20. COUNT III RESPONDENT FAILED TO SUBMIT ITS APPLICATIONS TO CERTIFY USE OF THE APPENDIX PROTOCOL FOR UNITS C AND D IN LIEU OF NITROGEN OXIDES CEMS TO