COMPLAINT FILED 6/9/99 PROPOSING A PENALTY OF $13,312. COMPLAINT ALLEGES: RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1998, TO THE LEPC, THE SERC OR THE APPROPRIATE FIRE DEPARTMENT. 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 OR THE APPROPRIATE FIRE DEPARTMENT. IN VIOLATION OF EPCRA SECTION 312(A). COUNT III RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1995, TO THE LEPC, THE SERC, OR THE APPROPRIATE FIRE DEPARTMENT. IN VIOLATION OF EPCRA SECTION 312(A). CACO ISSUED 6/9/99 ASSESSING A PENALTY OF $2,328. RESPONDEN SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPONDENT ALSO AGREES TO COMPLETE A SEP.