COMPLAINT FILED 11/12/97. COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO TIMELY SUBMIT A FORM R FOR NITRIC ACID FOR CALENDAR YEAR 1994. IN VIOLATION OF EPCRA SECTION 313. COUNT II RESPONDENT FAILED TO TIMELY SUBMIT A FORM R FOR SULFURIC ACID FOR THE CALENDAR YEAR 1994. IN VIOLATIN OF EPCRA SECTION 313. COUNT III RESPONDENT FAILED TO TIMELY SUBMIT A FORM R FOR SULFURIC ACID FOR CALENAR YEAR 1995. IN VIOLATION OF ECPRA SECTION 313. CACO ISSUED 11/12/97. RESPONDENT VOLUNTARILY DISCLOSED THE VIOLATIONS ALLEGED IN THE COMPLAINT IN ACCORDANCE ITH EPA'S POLICY - INCENTIVES FOR SELF-POLICING: DISCOVEY, DISCLOSURE, CORRECTION AND PREVENTION OF VIOLATIONS. (AUDIT POLICY) THEREFORE, EPA IS MITIGATING THE FULL AMOUNT OF THE PENALTY PROPOSED.