COMPLAINT FILED 9/23/99 PROPOSING A PENALTY OF $31,127 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 LIQUID ASHPHALT, DIESEL FUEL AND INDUSTRIAL BURNER FUEL TO THE LEPC, THE SERC, AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 311. COUNTS II & III RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY (TIER I OR TIER II) THAT LISTED LIQUID ASPHALT, DIESEL FUEL AND INDUSTRIAL FUEL AND INDUSTRIAL FUEL BY MARCH 1, 1999 AND MARCH 1, 1998, TO THE LEPC, THE SERCK AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. COUNT IV - MARCH 1, 1997. IN VIOLATION OF EPCRA SECTION 312(A). CACO ISSUED 9/27/99 ASSESSING A PENALTY OF $3,891. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPON- DENT ALSO AGREES A SEP.