COMPLAINT FILED 11/12/97. COMPLAINT ALLEGES: RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM FOR ANHYDROUS AMMONIA, FOR CALENDAR YEAR 1995, TO THE SERC, THE LEPC, AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY BY MARCH 1, 1996. IN VIOLATION OF EPCRA SECTION 312.