COMPLAINT ALLEGES 110 COUNTS OF FAILURE TO SUBMIT A PMN TO THE EPA PRIOR TO MANUFACTURING A NEW CHEMICAL SUBSTANCE AND ONE COUNT OF FAILING TO SUBMIT THE 1994 INVENTORY UPDATE REPORT TO THE EPA FOR CHEMICAL B DURING THE REPORTING PERIOD FROM 8/25/94 TO 12/23/94. CACO ISSUED 12/19/97 ASSESSING A PENALTY OF $14,450. RESPONDENT SHALL MAKE FIRST PAYMENT OF $2,000 BY JANUARY 15, 1998. LAST PAYMENT DUE BY JANUARY 15, 2000.