COMPLAINT FILED 5/29/98 PROPOSING A PENALTY OF $75,000 COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT A FORM R CONCERNING ETHYLENE GLYCOL TO THE ADMINISTRATOR OF EPA AND THE OFFICIAL DESIGNATED BY THE GOVERNOR OF THE STATE OF FLORIDA BY JULY 1, 1993. IN VIOLATION OF EPCRA SECTION 313. COUNT II RESPONDENT DID NOT SUBMIT A FORM R CONCERNING CHROMIUM TO THE ADMINISTRATOR OF THE EPA AND THE OFFICIAL DESIGNATED BY THE GOVERNOR OF THE STATE OF FLORIDA BY JULY 1, 1994. IN VIOLATION OF EPCRA SECTION 313. COUNT III RESPONDENT DID NOT SUBMIT A FORM R CONCERNING MAGNESIUM TO THE ADMINISTRATOR OF THE EPA AND THE OFFICIAL DESIGNATED BY THE GOVERNOR OF THE STATE OF FLORIDA BY JULY 1, 1995. IN VIOLATION OF EPCRA SECTION 313.