COMPLAINT FILED 9/30/98 PROPOSING A PENALTY OF $45,000. COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO FILE AN ACCURATE ANNUAL REPORT FOR THE EMELLE FACILITY FOR CALENDAR YEAR 1995 BY JULY 15, 1996. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.180(B) (3). COUNT II RESPONDENT FAILED TO FILE AN ACCURATE ANNUAL REPORT FOR THE EMELLE FACILITY FOR CALENDAR YEAR 1996 BY JULY 15, 1997. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.180(B) (3). CACO ISSUED 11/16/98 ASSESSING A PENALTY OF $19,952. RESPONDENT ALSO AGREES TO COMPLETE A SEP.