COMPLAINT FILED 9/23/99 PROPOSING A PENALTY $66,777. 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 4,4-DIPHENYLMETHANE DIISOCYANATE TO THE LEPC AND THE SERC. IN VIOLATION OF EPCRA SECTION 311. COUNTS II, III, IV RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM THAT LISTED 4,4 DIPHENYLMETHANE DIISOYANATE BY MARCH 1, 1999, MARCH 1, 1998, MARCH 1, 1997 TO THE LEPC, SERC, AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). COUNTS V, VI, VII RESPONDENT DID NOT SUBMIT A FORM R COVERING DIISOCYANATES TO THE ADMINISTRATOR OF EPA OR TO THE OFFICIAL DESIGNATED BY THE GOVERNOR OF THE STATE OF GEORGIA BY JULY 1, 1998, SEPTEMBER 1, 1997, AUGUST 1, 1996. IN VIOLATION OF EPCRA SECTION 313.