COMPLAINT FILED 7/30/99 PROPOSING A PENALTY OF $13,750. COMPLAINT ALLEGES: RESPONDENT FAILED TO IMMEDIATELY NOTIFY THE NRC AS SOON RESPONDENT HAD KNOWLEDGE OF THE RELEASE OF CHLORINE IN AN AMOUNT EQUAL TO OR GREATER THAN THE RQ FROM ITS FACILITY. IN VIOLATION OF CERCLA 103(A). CACO ISSUED 7/30/99 ASSESSING A PENALTY OF $2,234. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPONDENT ALSO AGREES TO COMPLETE A SEP.