THIS COMPLAINT AND CONSENT AGREEMENT ALLEGES THAT THE RESPONDENT FAILED TO FILE REPORTS AS REQUIRED BY EPCRA. COMPANIES THAT STORE HAZARDOUS CHEMICALS IN EXCESS OF ESTABLISHED THRESHOLD AMOUNTS FILE ANNUAL INVENTORY REPORTS. THE RESPONDENT FAILED TO FILE TIMELY TIER II REPORTS FOR CALENDAR YEARS 1997 AND 1998. THE PENALTY ASSESSED FOR THESE VIOLATIONS IS $7,000 TO BE PAID IN 8 QUARTERLY INSTALLMENTS OF $875.00. THE FIRST OF THESE PAYMENTS IS DUE OCTOBER 30, 1999.