VIOLATOR FAILED TO FILE TIMELY AN MSDS FOR COBALT UNTIL 1998 IN VIOLATION OF EPCRA 311 AND FAILED TO SUBMIT TIMELY THE ANNUAL REPORTS FOR TIER I AOR TIER II INFORMATION TO THE SERC, LEPC AND LOCAL FIRE COMPANY FOR THE YEARS 1994, 1995, AND 1996 FOR COBALT AS REQUIRED BY EPCRA SECTION 312. A ZERO PENALTY NON HAS BEEN ISSUED AND THE VIOLATORS REQUEST FOR TREATMENT UNDER THE SMALL BUSINESS COMPLIANCE POLICY WAS DENIED BECAUSE THE VIOLATOR FAILED TO CORRECT THE SECTION 312 VIOLATIONS WITHIN 90 DAYS AFTER DISCOVERY.