SEE ALSO PREVIOUS OTHER MATTER 04-98-0042 (ARCHIVED) COMPLAINT FILED 4/10/98 PROPOSING A PENALTY OF $7,637. COMPLAINT ALLEGES: COUNT I 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 BY MARCH 1, 1996. IN VIOLATION OF EPCRA 312. COUNT II RESPONDENT FAILED TO SUBMIT A FORM R FOR CALENDAR YEAR 1995 TO THE ADMINISTRATOR OF EPA AND TO THE STATE OF TENNESSEE ON OR BEFORE 8/1/96. CACO ISSUED 4/10/98 ASSESSING A PENALTY OF $1,909. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPONDENT ALSO AGREES TO COMPLETE A SEP.