COMPLAINT FILED 9/28/98 PROPOSING A PENALTY OF $16,502. COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT IMMEDIATELY NOTIFY THE NATIONAL RESPONSE CENTER OF THE RELEASE AS SOON AS RESPONDENT HAD KNOWLEDGE OF THE RELEASE. IN VIOLATION OF CERCLA SECTION 103(A). COUNT II RESPONDENT DID NOT SUBMIT, ON OR BEFORE OCTOBER 17, 1987, OR WITHIN THREE MONTHS AFTER IT BECAME SUBJECT TO OSHA'S MSDS REQUIREMENTS, MSDS FOR THIOUREA DIOXIDE TO THE LEPC, THE SERC OR THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 311. CACO ISSUED 9/28/98 ASSESSING A PENALTY OF $3,094. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPONDENT ALSO AGREES TO COMPLETE A SEP.