COMPLAINT FILED 6/10/98 PROPOSING A PENALTY OF $19,800 COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT FOR THE LOUISVILLE FACILITY, ON OR BEFORE OCTOBER 17, 1987, OR WITHIN 3 MONTHS AFTER RESPONDENT FIRST BECAME SUBJECT TO OSHA'S MSDS REQUIREMENTS, AN MSDS OR A LIST INCLUDING THE REQUIRED INFORMATION ABOUT DIESEL FUEL TO THE LEPC, THE SERC, AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE LOUISVILLE FACILITY. IN VIOLATION OF EPCRA SECTION 311. COUNT II RESPONDENT DID NOT SUBMIT FOR THE INDEPENDENCE FACILITY, ON OR BEFORE OCTOBER 17, 1987, OR WITHIN 3 MONTHS AFTER RESPONDENT FIRST BECAME SUBJECT TO OSHA'S MSDS REQUIREMENTS, AN MSDS OR A LIST INCLUDING THE REQUIRED INFORMATION ABOUT DIESEL FUEL TO THE LEPC, THE SERC, AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE INDEPENDENCE FACILITY. IN VIOLATION OF EPCRA SECTION 311. COUNT III RESPONDENT FAILED TO SUBMIT FOR THE LOUISVILLE FACILITY A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1997, TO THE LEPC, THE SERC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). COUNT IV