COMPLAINT FILED 6/22/2000 PROPOSING A PENALTY OF $15,250. COMPLAINT ALLEGES: COUNT I 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). COUNTS II & III RESPONDENT FAILED TO SUBMIT A COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY BY MARCH 1, 1997, MARCH 1, 1996 TO THE LEPC, THE SERC AND THE FIRE DEPARTMENT WITH JURISDIC- TION OVER THE FACILITY. IN VIOLATION OF EPCRA SECTION 312(A) CAFO ISSUED 6/22/2000 ASSESSING A PENALTY OF $3,984. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPONDENT ALSO AGREES TO COMPLETE A SEP. REDS NO: 2000 062 64Y 10G HYL