THIS IS A 15 COUNT COMPLAINT ALLEGING THAT THE RESPONDENT FAILED TO SUBMIT FORM R FOR CHROMIUM IN 1989 AND 1991, FAILED TO SUBMIT FORM R FOR LEAD AND LEAD COMPOUNDS IN 1989 AND 1991, FAILED TO SUBMIT FORM R FOR TOLUENE IN 1989, 1991 AND 1993, FAILED TO SUBMIT FORM R FOR XYLENE IN 1989, 1991 AND 1993, AND FAILED TO SUBMIT FORM R FOR ETHYLBENZENE, ACE- TONE AND ETHLENE GLYCOL IN 1989. A FEDERAL PENALTY OF $37,934 WAS PROPOSED.