COMPLAINT FILED 4/10/98 PROPOSING A PENALTY OF $22,000. COMPLAINT ALLEGES: RESPONDENT FAILED TO SUBMIT A TIER I OR TIER II FOR HYDROQUINONE BY MARCH 1, 1997 TO THE SERC/LEPC OR THE FIRE DEPARTMENT WITH JURISDICITION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). CACO ISSUED 4/10/98 ASSESSING A PENALTY OF $15,400. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS.