COMPLAINT FILED 9/24/99 PROPOSING PENALTY OF $22,345 COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO IMMEDIATELY NOTIFY THE NRC AS SOON AS RESPONDENT HAD KNOWLEDGE OF THE RELEASE OF AMMONIA IN AN AMOUNT EQUAL TO OR GREATER THAN THE RQ AT ITS FACILITY AND ITS FACILITY. IN VIOLATION OF CERCLA SECTION 103(A). COUNT II RESPONDENT DID NOT NOTIFY THE SERC OF THE RELEASE AS RE- QUIRED UNDER EPCRA SECTION 304(A). CACO ISSUED 9/24/99 ASSESSING A PENALTY OF $5,587. EPCRA VIOLATION - $2,291, CERCLA VIOLATION - $3,296.