COUNT 1 - RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM FOR AMMONIA FOR CALENDAR YEAR 1994 TO THE SERC, THE LEPC, AND THE FIRE DEPT WITH JURISDICTION OVER THE FACILITY BY MARCH 1, 1995, AS REQUIRED BY SECTION 312 OF EPCRA. COUNT 2 - RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1996, TO THE LEPC, THE SERC, AND THE FIRE DEPT. WITH JURISDICTION OVER THE FACILITY; IN VIOLATION OF SECTION 312(A) OF EPCRA. COUNT 3 - RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1997 TO THE LEPC, THE SERC, AND THE FIRE DEPT WITH JURISDICTION OVER THE FACILITY; IN VIOLATION OF SECTION 312(A) OF EPCRA.