COMPLAINT FILED 9/29/99 PROPOSING A PENALTY OF $64,139. COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO SUBMIT A FORM FOR 1,1,1-TRICHLOROETHANE FOR CALENDAR YEAR 1997 BY JULY 1, 1998. IN VIOLATION OF EPCRA SECTION 313. COUNT II RESPONDENT FAILED TO SUBMIT A FORM R FOR 1, 1, 1- TRICHLOROETHANE FOR CALENDAR YEAR 1996 BY 9/8/97. IN VIOLATION OF EPCRA SECTION 313 COUNT III RESPONDENT DID NOT SUBMIT A FORMR COVERING 1,1,1-TRICHLORO- ETHANE FOR ITS GREENVILLE, SOUTH CAROLINA FACILITY TO THE ADMINISTRATOR OF EPA NOR TO THE OFFICIAL DESIGNATED BY THE GOVERNOR OF SOUTH CAROLINA FOR CALENDAR YEAR 1995 BY 8/1/96. IN VIOLATION OF EPCRA SECTION 313. CACO ISSUED 1/24/2000 ASSESSING A PENALTY OF $9,621. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPONDEN RESPONDENT ALSO AGREES TO COMPLETE A SEP.