COMPLAINT FILED 3/25/98 PROPOSING A PENALTY OF $22,667. COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT, ON OR BEFORE OCTOBER 17, 1987, OR WITHIN THREE (3) MONTHS AFTER IT BECAME SUBJECT TO OSHA'S MSDS REQUIREMENTS, MSDSS FOR DIESEL FUEL AND GASOLINE OR A LIST OF THE TWO (2) HAZARDOUS CHEMICALS TO THE SERC. IN VIOLATION OF EPCRA SECTION 311. COUNT II RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM FOR DIESEL FUEL AND GASOLINE FOR CALENDAR YEAR 1995 TO THE SERC, THE LEPC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY BY MARCH 1, 1996, AS REQUIRED. IN VIOLATION OF EPCRA SECTION 312(A). CACO ISSUED 3/25/98 ASSESSING A PENALTY OF $2,975. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAY. RESPONDENT ALSO AGREES TO COMPLETE A SEP.