COMPLAINT FILED 7/17/98 PROPOSING A PENALTY OF $84,000 COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT A FORM R COVERING COPPER TO THE ADMINISTRATOR OF EPA OR THE OFFICIAL DESIGNATED BY THE GOVERNOR OF TENNESSEE FOR CALENDAR 1995 BY AUGUST 1, 1996. IN VIOLATION OF EPCRA SECTION 313. COUNT II RESPONDENT DID NOT SUBMIT A FORM R COVERING NICKEL TO THE ADMINISTRATOR OF EPA OR THE OFFICIAL DESIGNATED BY THE GOVERNOR OF TENNESSEE FOR CALENDAR 1995 BY AUGUST 1, 1996. IN VIOLATION OF EPCRA SECTION 313. COUNT III RESPONDENT DID NOT SUBMIT FORM R COVERING MANGANESE, BY AUGUST 1, 1996. COUNT IV RESPONDENT DID NOT SUBMIT FORM R COVERING COBALT, BY AUGUST 1, 1996. CACO ISSUED 7/17/98, RESPONDENT VOLUNTARILY DISCLOSED THE VIOLATIONS ALLEGED IN THE COMPLAINT IN ACCORDAN