COMPLAINT FILED 6/11/99 PROPOSING A PENALTY OF $227,689. COMPLAINT ALLEGES: (32 VIOLATIONS OF EPCRA SECTIONS 302, 303, 311, 312 & 313) CACO ISSUED 6/11/99, RESPONDENT VOLUNTARILY DISCLOSED THE EPCRA VIOLATIONS ALLEGED IN THE COMPLAINT IN ACCORDANCE WITH THE EPA POLICY INCENTIVES FOR SELF-POLICING: DISCOVERY DISCLOSURE, CORRECTION AND PREVENTION OF VIOLATIONS, (SELF- DISCLOSURE POLICY). 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 PROPOSED IN THE COMPLAINT.