COMPLAINT FILED 9/30/99 PROPOSING A PENALTY OF $22,252. 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 PROPANE AND FUEL OIL TO THE LEPC, THE SERC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 311. COUNTS II, III, & IV RESPONDENT FAILED TO SUBMIT COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORMS (TIER I OR TIER II) THAT LISTED PROPANE AND FUEL OIL BY MARCH 1, 1996, MARCH 1, 1997, AND MARCH 1, 1998, TO THE LEPC, THE SERC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). CACO ISSUED 9/30/99 ASSESSING A PENALTY OF $3,616. RESPON- DENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPONDENT ALSO AGREES TO COMPLETE A SEP.