COMPLAINT FILED 9/22/99 PROPOSING A PENALTY OF $43,627. COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT, ON OR BEFORE OCTOBER 17, 1987, OR WITHIN 3 MONTHS AFTER RESPONDENT FIRST BECAME SUBJECT TO OSHA'S MSDS REQUIREMENTS, AN MSDS OR A LIST INCLUDING THE REQUIRED INFORMATION ABOUT SULFUR DIOXIDE TO THE LEPC, THE SERC, AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 311. COUNTS II,III & IV RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM FOR CHLORINE FOR CALENDAR YEARS 1995, 1996 AND 1997 TO THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312. COUNT V RESPONDENT FAILED TO IMMEDIATELY NOTIFY THE NRC AS SOON AS RESPONDENT HAD KNOWLEDGE OF THE RELEASE OF SODIUM HYDROXIDE IN AN AMOUNT EQUAL TO OR GREATER THAN THE RQ FROM ITS FACILITY. CACO ISSUED 9/22/99 ASSESSING A PENALTY OF $5,170. EPCRA VIOLATIONS PENALTY TOTALED $3,139, CERCLA VIOLATION $2.031. PENALTY FOR EPCRA VIOLATION DUE WITHIN THIRTY DAYS. RESPONDENT ALSO AGREES TO COMPLETE A SEP. CACO AMENDED 3/7/2000 TO ADD THE PUR