COMPLAINT FILED 9/30/99 PROPOSING A PENALTY OF 84,506. COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT A MSDS FOR DIESEL FUEL OR A LIST CONTAINING DIESEL FUEL TO THE SERC WITHIN THREE MONTHS AFTER THE OWNER OR OPERATOR FIRST BECAME SUBJECT TO OSHA'S MSDS REQUIREMENTS AND FIRST REACHED OR EXCEEDED THE 10,000 THRES- HOLD AMOUNT FOR DIESEL FUEL. IN VIOLATION OF EPCRA SECTION 311. COUNTS II, III, IV RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM LISTING DIESEL FUEL FOR CALENDAR YEAR 1996, 1997, 1998 THE SERC, THE LEPC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER CONCRETE PLANT #1 FACILITY BY MARCH 1, 1998. IN VIOLATION OF EPCRA SECTION 312(A). COUNT V, RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND AND HAZARDOUS CHEMICAL INVENTORY FORM LISTING DIESEL FUEL FOR CALENDAR YEAR 1996 TO THE SERC, THE LEPC, AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE CONCRETE PLANT # FACILITY BY MARCH 1, 1997. IN VIOLATION EPCRA SECTION 312(A COUNT VI, VII RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM LI