COUNT 1: RESPONDENT DID NOT SUBMIT, ON OR BEFORE 10/17/87, OR WITHIN 3 MONTHS AFTER RESPONDENT FIRST BECAME SUBJECT TO OSHA'S MSDS REQUIREMENTS, AN MSDS OR A LIST INCLUDING THE REQUIRED INFO ABOUT DIESEL FUEL TO THE LEPC, THE SERC, AND THE FIRE DEPT WITH JURISDICTION OVER TEH FACILTY; IN VIOLATION OF SECTION 311 OF EPCRA. COUNT 2: RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1998 TO THE LEPC, THE SERC AND THE FIRE DEPT WITH JURISDICTION OVER THE FACILITY; IN VIOLATIN OF SECTION 312(A) OF EPCRA. COUNT 3: RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOU CHEMICAL INVENTORY FORM BY MARCH 1, 1997, TO THE LEPC, THE SERC, AND THE FIRE DEPT WITH JURISDICTION OVER THE FACILITY; IN VIOLATION OF SECTION 312(A) OF EPCRA. COUNT 4: RESONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1996, TO THE LEPC, THE SERC, AND THE FIRE DEPT WITH JURISDICTION OVER THE FACILITY; IN VIOLATION OF SECTION 312(A) OF THE EPCRA.