COMPLAINT FILED 9/22/99 PROPOSING A PENALTY OF $31,417 COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT, ON OR BEFORE OCTOBER 17, 1987, OR WITHIN THREE MONTHS AFTER RESPONDENT FIRST BECAME SUBJECT TO OSHA'S MSDS REQUIREMENTS, AN MSDS OR A LIST INCLUDING THE REQUIRED INFORMATION ABOUT SULFURIC ACID TO THE LEPC, THE SERC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 311. COUNT II RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM (TIER I OR TIER II) THAT LISTED SULFURIC ACID BY MARCH 1, 1997, TO THE LEPC, THE SERC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). COUNT III RESPONDENT FAILED SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM (TIER I OR TIER II) THAT LISTED SULFURIC ACID BY MARCH 1, 1996, TO THE LEPC, THE SERC AND TH E FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). COUNT IV AT SOME TIME DURING CALENDAR YEAR 1994 SULFURIC ACID WAS PRESENT AT THE FACILITY IN AN AMOUNT EQUAL TO OR GREATER THAN THE 5OO-POUND THRESHOLD LEVELS