COMPLAINT FILED 2/25/98 COMPLAINT ALLEGES: RESPONDENT DID NOT SUBMIT, ON OR BEFORE OCTOBER 17, 1987, OR WITHIN 3 MONTHS AFTER RESPONDENT FIRST BECAME SUBJECT TO OSHA'S MSDS REQUIREMENT, AN MSDS OR A LIST INCLUDING THE REQUIRED INFORMATION ABOUT ETHYLENE GLYCOL, GASOLINE, DIESEL, MOTOR OIL, UNLEADED GAS AND AVIATION GAS. IN VIOLATION OF EPCRA SECTION 311. RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1996, TO THE SERC AND FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). CACO ISSUED 7/29/1999 ASSESSING A PENALTY OF $9,000, PAY- MENTS TO BE MADE WITHIN EIGHTEEN MONTHS.