COMPLAINT FILED 9/30/99 PROPOSING A PENALTY OF $41,250. COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO IMMEDIATELY NOTIFY THE NRC AS SOON AS RESPONDENT HAD KNOWLEDGE OF THE RELEASE OF AMMONIA IN AN AMOUNT EQUAL TO OR GREATER THAN THE RQ AT ITS FACILITY. IN VIOLATION OF CERCLA 103(A). COUNT II RESPONDENT VIOLATED THE NOTIFICATION REQUIREMENTS OF EPCRA SECTION 304(A). CACO ISSUED 9/30/99 ASSESSING A PENALTY OF $3,352. RESPON- DENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPONDENT ALSO AGREES COMPLETE A SEP.