COMPLAINT FILED 9/2/98 PROPOSING A PENALTY OF $94,948 COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO SUBMIT A FORM R FOR STYRENE FOR CALENDAR YEAR 1994. IN VIOLATION OF EPCRA SECTION 313. COUNT II RESPONDENT FAILED TO SUBMIT A FORM R FOR STYRENE FOR CALENDAR YEAR 1995. IN VIOLATION OF EPCRA SECTION 313. COUNT III RESPONDENT FAILED TO SUBMIT A FORM R FOR COPPER FOR CALENDAR YEAR 1993. IN VIOLATION OF EPCRA SECTION 313. COUNT IV RESPONDENT FAILED TO SUBMIT A FORM R FOR COPPER FOR CALENDAR YEAR 1994. IN VIOLATION OF EPCRA SECTION 313. COUNT V RESPONDENT FAILED TO SUBMIT A FORM R FOR COPPER FOR CALENDAR YEAR 1995. IN VIOLATION OF EPCRA SECTION 313. COUNT VI RESPONDENT FAILED TO SUBMIT A FOR R FOR COPPER FOR CALENDAR YEAR 1996. IN VIOLATION OF EPCRA SECTION 313. CACO ISSUED 9/2/98 ASSESSING A PENALTY OF $8,500. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS.