COMPLAINT FILED 10/7/99 PROPOSING A PENALTY OF $22,252. COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT SUBMIT, ON OR BEFORE 10/17/87, OR WITHIN E MONTHS AFTER RESPPONDENT FIRST BECAME SUBJECT TO OSHA'S MSDS REQUIREMENTS, AN MSDS OR A LIST INCLUDING THE REQUIRED INFORMATION ABOUT HOT ASPHALT TO THE LEPC, THE SERC, AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA 311. COUNT II - RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1998, TO THE LEPC, THE SERC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). COUNT III- RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1997, TO THE LEPC, SERC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). COUNT IV - RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORM BY MARCH 1, 1996, TO THE LEPC, THE SERC AND THE FIRE DEPARTMENT WITH JURISDICTION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A). CACO ISSUED 10/7/99 ASSESSING A PENALTY OF $11,126. RESPON- DENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS.