COMPLAINT FILED 6/10/98 PROPOSING A PENALTY OF $35,000 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 MDI TO THE LEPC, THE SERC, AND THE FIRE DEPARTMENT WITH JURISDICTIONOVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 311. COUNT II RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM THAT LISTED MDI 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 MDI TO THE ADMINISTRATOR OF EPA OR TO THE OFFICIAL DESIGNATED BY THE GOVERNOR OF THE STATE OF NORTH CAROLINA BY JULY 1, 1994. IN VIOLATION OF EPCRA SECTION 313. COUNT IV RESPONDENT DID NOT SUBMIT A FORM R COVERING MDI TO THE ADMINISTRATOR OF EPA OR THE THE OFFICIAL DESIGNATED BY THE GOVERNOR OF THE STATE OF NORTH CAROLINA BY JULY 1, 1995. IN VIOLATION OF EPCRA SECTION 313.