COMPLAINT FILED 1/21/99 PROPOSING A PENALTY OF $165,000 COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM FOR SODIUM HYDROXIDE, #2 FUEL OIL, LIQUABRADE 8533, SULFURIC ACID AND NITRIC ACID FOR CALENDAR YEAR 1996 TO THE SERC,THE LEPC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY BY MARCH 1, 1997. IN VIOLATION OF EPCRA SECTION 312. COUNT II RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM FOR SODIUM HYDROXIDE, #2 FUEL OIL, LIQUABRADE 8533, SULFURIC ACID AND NITRIC ACID FOR CALENDAR YEAR 1997 TO THE SERC, THE LEPC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY BY MARCH 1, 1998. IN VIOLATION OF EPCRA SECTION 312. CACO ISSUED 1/21/99. RESPONDENT VOLUNTARILY DISCLOSED THE VIOLATIONS ALLEGED IN THE COMPLAINT. EPA HAS DETERMINED THAT RESPONDENT HAS MET ALL CONDITIONS OUTLINED IN THE SELF-DISCLOSURE POLICY AND IS THEREFORE, PURSUANT TO THE POLICY, MITIGATING THE FULL AMOUNT OF THE PENALTY PROPOSED IN THE COMPLAINT. NO CIVIL PENALTY WILL BE ASSESSED.