COMPLAINT FILED 6/15/99 PROPOSING A PENALTY OF $17,751. COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM FOR POTASSSIUM CYANIDE AND 1,1,1-TRICHLOROETHANE FOR CALENDAR YEAR 1994 TO THE LEPC, THE SERC, AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY BY MARCH 1, 1995. IN VIOLATION OF EPCRA 312. COUNT II RESPONDENT DID NOT SUBMIT A FORM R COVERING 1,1,1- TRICHLOROETHANE TO THE ADMINISTRATOR OF EPA OR TO THE DESIGNATED BY THE GOVERNOR OF GEORGIA BY JULY 1, 1996. IN VIOLATION OF EPCRA 313. COUNT III RESPONDENT DID NOT SUBMIT A FORM R COVERING 1,1,1- TRICHLOROETHANE TO THE ADMINISTRATOR OF EPA OR TO THE DESIGNATED BY THE GOVERNOR OF GEORGIA BY JULY 1, 1995. IN VIOLATION OF EPCRA 313. CACO ISSUED 6/15/95 ASSESSING A PENALTY OF $3,106.50. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. PENALTY PAID. CASE CLOSED 7/20/99.