RESPONDENT FAILED TO PROVIDE MATERIAL SAFETY DATA SHEETS (MSDSS), OR A LIST OF MSDS CHEMICALS, WHICH INCLUDED EVERY HAZARDOUS CHEMICAL PRESENT AT THE FACILITY IN QUANTITIES GREATER THAN OR EQUAL TO THE THRESHOLD, TO THE STATE EMERGENCY RESPONSE COMMISSION (SERC), THE LOCAL EMERGENCY PLANNING COMMITTEE (LEPC), AND THE LOCAL FIRE DEPARTMENT, IN VIOLATION OF EPCRA SECTION 311. RESPONDENT ADDITIONALLY FAILED TO PROVIDE AN EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM CONTAINING TIER I OR TIER II INFORMATION WITH RESPECT TO THE PRECEDING CALENDAR YEAR FOR EVERY HAZARDOUS CHEMICAL PRESENT AT THE FACILITY IN QUANTITIES GREATER THAN OR EQUAL TO THE THRESHOLD, TO THE SERC, THE LEPC, AND LOCAL FIRE DEPARTMENT FOR THE CALENDAR YEARS 1995, 1996, AND 1997, IN VIOLATION OF EPCRA SECTION 312.