RESPONDENT FAILED TO SUBMIT A MATERIAL SAFETY DATA SHEET FOR SULFURIC ACID, AS REQUIRED BY SECTION 311 OF EPCRA, FAILED TO SUBMIT TIER I/II FORMS FOR SULFURIC ACID FOR 1997, 1996 AND 1995 TO THE STATE AGENCY, LOCAL EMERGENCY PLANNING COMMISSION AND THE FIRE DEPARTMENT, AS REQUIRED BY SECTION 312 OF EPCRA AND FAILED TO SUBMIT TOXIC CHEMICAL INVENTORY FORMS RS FOR PHOSPHORIC ACID FOR YEARS 1995 AND 1996 AS RE- QUIRED BY SECTION 313.