COMPLAINT FILED 5/21/99 PROPOSING A PENALTY OF $11,800 COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1997, TO THE LEPC, THE SERC AND THE LOCAL FIRE DEPARTMENT WITH JURIS- DICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). COUNT II RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1996, TO THE LEPC, THE SERC AND THE LOCAL FIRE DEPARTMENT WITH JURIS- DICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). CACO ISSUED 5/21/99 ASSESSING A PENALTY OF $5,900. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS.