COMPLAINT FILED 6/10/98 PROPOSING A PENALTY OF $66,500 COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO SUBMIT A PMN TO EPA AT LEAST 90 DAYS PRIOR TO IMPORTING CHEMICAL A INTO THE CUSTOMS TERRITORY OF THE UNITED STATES. IN VIOLATION OF TSCA 40 C.F.R. SECTION 720.22(B) (1). COUNT II ON OR ABOUT JULY 22, 1994, RESPONDENT IMPORTED 1,000 KILOGRAMS OF CHEMICAL A INTO THE CUSTOMS TERRITORY OF THE UNITED STATES VIA JAMAICA, NEW YORK. RESPONDENT FAILED TO SUBMIT A PMN TO EPA PRIOR TO IMPORTING CHEMICAL A INTO THE CUSTOMS TERRITORY OF THE UNITED STATES. IN VIOLATION OF TSCA 40 C.F.R. SECTION 720.22(B) (1). COUNT III ON OR ABOUT AUGUST 19, 1994, RESPONDENT IMPORTED 400 KILOGRAMS OF CHEMICAL A INTO THE CUSTOMS TERRITORY OF THE UNITED STATES VIA JAMAICA, NEW YORK. RESPONDENT FAILED TO SUBMIT A PMN TO EPA PRIOR TO IMPORTING