COMPLAINT FILED 4/2/98 PROPOSING A PENALTY OF $9,900. COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT, ON OR BEFORE OCTOBER 17, 1987, OR WITHIN 3 MONTHS AFTER RESPONDENT FIRST BECAMBE SUBJET TO OSHA'S MSDS REQUIREMENTS, AN MSDS OR A LIST INCLUDING TH REQUIRED INFORMATION ABOUT DIESEL FUEL TO THE LEPC, THE SERC, AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 311. COUNT II RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1997, TO THE LEPC, THE SEC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). CACO ISSUED 4/2/98 ASSESSING A PENALTY OF $1,261. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPONDENT ALSO AGREES TO COMPLETE A SEP.