COMPLAINT FILED 6/18/99 PROPOSING A PENALTY OF $150,000. COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT A FORM R COVERING TOLUENE TO THE ADMINISTRATOR OF EPA, OR THE OFFICIAL DESIGNATED BY THE GOVERNOR OF SOUTH CAROLINA, FOR CALENDAR YEAR 1994, BY THE DEADLINE OF JULY 1, 1995. IN VIOLATION OF EPCRA SECTION 313. COUNT II RESPONDENT DID NOT SUBMIT A FORM R COVERING TOLUENE TO THE ADMINISTRATOR OF EPA, OR THE OFFICIAL DESIGNATED BY THE GOVERNOR OF SOUTH CAROLINA, FOR CALENDAR YEAR 1995, BY THE EXTENDED DEADLINE OF AUGUST 1, 1996. IN VIOLATION OF EPCRA SECTION 313. COUNT III RESPONDENT DID NOT SUBMIT A FORM R COVERING TOLUENE TO THE ADMINISTRATOR OF EPA, OR THE OFFICIAL DESIGNATED BY THE GOVERNOR OF SOUTH CAROLINA, FOR CALENDAR 1996, BY THE EXTEND DEADLINE OF SEPTEMBER 8, 1997. IN VIOLATION OF EPCRA SECTION 313. CACO ISSUED 6/18/99. RESPONDENT VOLUNTARILY DISCLOSED THE VIOLATIONS ALLEGED IN THE COMPLAINT IN ACCORDANCE WITH EPA'S POLICY - INCENTIVES FOR SELF-POLICING: DISCOVERY, DISCLOSUR CORRECTION AND PREVENTION OF VIOLATIONS. EPA HAS DETERMINED THAT RESPONDENT HAS MET A