COMPLAINT FILED 9/21/2001 PROPOSING A PENALTY OF $74,800. COUNT I - RESPONDENT DID NOT SUBMIT INFORMATION ON CHEMICAL A DURING THE 1998 PERIOD. COUNT II - RESPONDENT DID NOT SUBMIT INFORMATION ON CHEMICAL B DURING THE 1998 PERIOD. COUNT III - RESPONDENT DID NOT SUBMIT INFORMATION ON CHEMICAL C DURING THE 1998 PERIOD. COUNT IV - RESPONDENT DID NOT SUBMIT INFORMATION ON CHEMICAL D DURING THE 1998 PERIOD. IN VIOLATION OF OF TSCA SECTION 8(A).