COMPLAINT FILED 4/24/98 PROPOSING A PENALTY OF $56,885. COUNT I RESPONDENT DID NOT SUBMIT, ON OR BEFORE OCTOBER 17, 1987, OR WITHIN THREE MONTHS AFTER RESPONDENT FIRST BECAME SUBJECT OSHA'S MSDS REQUIREMENTS, AN MSDS OR A LIST INCLUDING THE REQUIRED INFORMATION, TO THE SERC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 311. COUNT II RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM FOR CALENDAR YEAR 1995 TO THE SERC AND FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY BY MARCH 1, 1996. IN VIOLATION OF EPCRA SECTION 312(A). COUNT III RESPONDENT DID NOT SUBMIT A FORM R FOR STYRENE TO THE ADMINISTRATOR OF EPA AND THE OFFICIAL DESIGNATED BY THE GOVERNOR OF THE STATE OF GEORGIA BY AUGUST 1, 1997, THE DATE THE DEAD