COMPLAINT FILED 1/19/99 PROPOSING A PENALTY OF $13,400 COMPLAINT ALLEGES: RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1998, TO THE LEPC, THE SERC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312. CACO ISSUED 1/19/99 ASSESSING A PENALTY OF $2,680. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPONDEN ALSO AGREES TO COMPLETE A SEP.