COUNT I: FAILURE TO SUBMIT BY MARCH 1, 1998 TO THE SERC, AN EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM IDENTIFYING AND PROVIDING INFORMATION CONCERNING AMMONIA (ANHYDROUS) AT RESPONDENT'S FACILITY IN 1997 IN VIOLATION OF EPCRA SECTION 312 OF EPCRA, 42 U.S.C. SECTION 11022, AND 40 C.F.R PART 370.25.