COMPLAINT FILED 9/16/99 PROPOSING A PENALTY OF $144,630. COMPLAINT ALLEGES: COUNTS I, II & III RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZAROUS CHEMICAL INVENTORY FOR AMMONIA FOR CALENDAR YEARS 1995, 1996 & 1997. IN VIOLATION OF EPCRA SECTION 312(A). COUNTS IV, V, & VI RESPONDENT FAILED TO SUBMIT A FORM R FOR COBALT FOR CALENDAR YEARS 1995, 1996 & 1997 TO THE ADMINISTRATOR OF EPA AND TO THE STATE OF SOUTH CAROLINA. IN VIOLATION OF EPCRA SECTION 313. COUNTS VII, VIII, IX RESPONDENT FAILED TO A FORM R FORM AMMONIA FOR CALENDAR YEARS 1995, 1996 & 1997 TO THE ADMINISTRATOR OF EPA AND TO THE STATE OF SOUTH CAROLINA. IN VILOLATION OF EPCRA SECTION 313. CACO ISSUED 9/16/99 ASSESSING A PENALTY OF $26,130. RESPONDENT ALSO AGREES TO COMPLETE A SEP.