COMPLAINT FILED 9/23/99 PROPOSING A PENALTY OF $19,252. COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT, ON OR BEFORE 10/17/87, OR WITHIN THREE MONTHS AFTER RESPONDENT FIRST BECAME SUBJECTS TO OSHA'S MSDS REQUIREMENTS, AN MSDS OR A LIST INCLUDING THE REQUIRED INFORMATION ABOUT DIESEL FUEL TO THE LEPC, THE SERC AND THE FIRE DEPARTMENT OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 311. COUNT II RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM (TIER I OR TIER II) THAT LISTED DIESEL FUEL BY MARCH 1, 1999, TO THE LEPC, THE SERC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. 12/20/99 - CACO ISSUED, ASSESSING A PENALTY OF $3,129. RESPONDENT ALSO AGREES TO COMPLETE A SEP. REDS NO. 2000 0225 467 82059