COMPLAINT FILED 6/1/98 PROPOSING A PENALTY OF $82,850 COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT, ON OR BEFORE OCTOBER 17, 1987 OR WITHIN 3 MONTHS AFTER RESPONDENT FIRST BECAME SUBJECT TO OSHA'S MSDS REQUIREMENTS, AN MSDS OR A LIST INCLUDING THE REQUIRED INFORMATION ABOUT SULFURIC ACID TO THE LEPC, 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 THAT LISTED SULFURIC ACID BY MARCH 1, 1996, TO THE LEPC, THE SERC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). COUNT III RESPONDENT DID NOT SUBMIT A FORM R COVERING SULFURIC ACID TO THE ADMINISTRATOR OF EPA OR TO THE OFFICIAL DESIGNATED BY THE GOVERNOR OF