COMPLAINT FILED 1/14/98 PROPOSING A PENALTY OF $2,000. COMPLAINT ALLEGES: RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM FOR AMMONIA, FOR CALENDAR YEAR 1995, TO THE SERC, THE LEPC, AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312. CACO ISSUED 2/17/98 ASSESSING A PENALTY OF $1,000. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPONDENT ALSO AGREES TO COMPLETE A SEP.