COMPLAINT FILED 6/29/98 PROPOSING A PENALTY OF $78,000 COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT A FORM R COVERING GLYCOL ETHERS TO THE ADMINISTRATOR OF EPA THE OFFICIAL DESIGNATED BY THE GOVERNOR OF SOUTH CAROLINA FOR CALENDAR YEAR BY JULY 1, 1995. IN VIOLATION OF EPCRA SECTION 313. COUNT II RESPONDENT FAILED TO TIMELY SUBMIT A FORM R COVERING GLYCOL EHTERS FOR CALENDAR YEAR 1995 BY AUGUST 1, 1996. IN VIOLATION OF EPCRA SECTION 313. COUNT III RESPONDENT FAILED TO SUBMIT A FORM R COVERING SODIUM NITRITE TO THE ADMINISTRATOR OF EPA OR THE OFFICIAL DESIGNATED BY THE GOVERNOR OF SOUTH CAROLINA FOR CALENDAR YEAR 1995 BY AUGUST 1, 1996. IN VIOLATION OF EPCRA SECTION 313. COUNT IV