COMPLAINT ALLEGES: COUNT I- V RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM FOR AMMONIA, FOR CALENDAR YEAR 1991, 1992, 1993, 1994 AND 1995 TO THE SERC, THE LEPC, AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY BY MARCH 1, 1992, MARCH 1, 1993, MARCH 1, 1994, MARCH 1, 1995 AND MARCH 6, 1996. IN VIOLATION OF EPCRA SECTION 312(A). CACO ISSUED 11/12/97 ASSESSING A PENALTY OF $2,000. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. COUNT III