COMPLAINT FILED 12/23/99 PROPOSING A PENALTY OF $45,326. COMPLAINT ALLEGES: COUNT I - RESPONDENT DID NOT SUBMIT A FORM R COVERING DIISOCYANATES TO THE ADMINISTRATOR OF EPA OR TO THE OFFICIAL DESIGNATED BY THE GOVERNOR OF THE STATE OF GEORGIA FOR CALENDAR YEAR 1996 BY THE EXTENDED DEADLINE OF 9/8/97. IN VIOLATION OF EPCRA SECTION 313. COUNT II - RESPONDENT DID NOT SUBMIT A FORM R COVERING DIISOYANATES TO THE ADMINISTRATOR OF EPA OR TO THE OFFICIAL DESIGNATED BY THE GOVERNOR OF THE STATE OF GEORGIA FOR CALENDAR YEAR 1997 BY THE DEADLINE OF JULY 1, 1998. IN VIOLATION OF EPCRA SECTION 313. COUNT III - RESPONDENT DID NOT SUBMIT A FORM A IN LIEU OF A FORM R COVERING DIISOCYANATES TO THE ADMINISTRATOR OF EPA OR TO THE OFFICIAL DESIGNATED BY THE GOVERNOR OF THE STATE OF GEORGIA FOR CALENDAR YEAR 1998 BY JULY 1, 1999. RESPONDENT DID SUBMIT A FORM A ON AUGUST 10, 1999. IN VIOLATION OF EPCRA SECTION 313.