This is a Complaint, Consent Agreement, and Final Order ( CAFO ) pursuant to Section 312 of EPCRA issued to Pima Chemical LLC. The violations involve failure to timely submit Annual Completed Emergency and Hazardous Chemical Inventory Form report to the appropriate state and local authorities for three consecutive years, 1998, 1999 and 2000. In the CAFO, Respondent agrees to pay the full $12,995 penalty sought by EPA.