RESPONDENT DID NOT SUBMIT, ON OR BEFORE OCTOBER 17, 1987, AN MSDS OR A LIST INCLUDING THE REQUIRED INFO ABOUT THE CHEMICALS LISTED TO THE LEPC, THE SERC, AND THE FIRE DEPT WITH JURISDICTION OVER THE FACILITY, IN VIOLATION OF SECTION 311 OF EPCRA; RESPONDENT FAILED TO SUBMIT COMPLETED EMERGENCY AND HAZARDOUS CHEMICAL INVENTORY FORMS FOR THE CHEMICALS LISTED FOR CALENDAR YEAR 1999 TO THE LEPC, THE SERC AND THE APPROPRIATE FIRE DEPT BY MARCH 1, IN VIOLATION OF 312 OF EPCRA; RESPONDENT FAILED TO SUBMIT A FORM R FOR CALENDAR YEAR 1998, IN VIOLATION OF SECTION 313 OF EPCRA.