COMPLAINT FILED 9/30/99 PROPOSING A PENALTY OF $27,377. COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT, ON OR BEFORE OCTOBER 17, 1987, OR WITHIN THREE MONTHS AFTER RESPONDENT FIRST BECAME SUBJECT TO OSHA'S MSDS REQUIREMENTS, AN MSDS OR A LIST INCLUDING THE REQUIRED INFORMATION ABOUT LIQUID ASPHALT AND DIESEL FUEL 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 (TIER I OR TIER II) THAT LISTED LIQUID ASPHALT AND DIESEL FUEL BY MARCH 1, 1999, MARCH 1, 1998 AND MARCH 1, 1997, TO THE LEPC, THE SERC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). CACO ISSUED 10/8/99 ASSESSING A PENALTY OF $4,449. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPON- DENT ALSO AGREES TO COMPLETE A SEP.