COMPLAINT FILED 9/30/99 PROPOSING A PENALTY OF $40,500 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 SULFURIC ACID AND PROPIONIC ACID TO THE LEPC, THE SERC, AND THE FIRE DEPARTMENT WITH JURIS- DICITON 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 THAT LISTED SULFURIC ACID AND PROPIONIC ACID 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 $5,062. RESPON- ALSO AGREES TO COMPLETE A SEP.