COMPLAINT FILED 12/4/98 PROPOSING A PENALTY OF $23,626. COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1998, TO THE SERC. IN VIOLATION OF EPCRA SECTION 312(A). COUNT II RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1997, TO THE SERC. IN VIOLATION OF EPCRA SECTION 312(A). COUNT III RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1996, TO THE SERC. IN VIOLATION OF EPCRA SECTION 312(A). CACO ISSUED 12/4/98 ASSESSING A PENALTY OF $15,948. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS.