THE COMPLAINT ALLEGES 57 COUNTS FOR VIOLATIONS OF EPCRA AND CERCLA, AND SOUGHT $911,250 IN PENALTIES, DUE TO THE RESPONDENT'S FAILURE TO GIVE IMMEDIATE NOTICE TO THE NATIONAL RESPONSE CENTER AND THE STATE AND LOCAL RESPONSE AUTHORITIES OF RELEASES THAT EXCEEDED REPORTABLE QUANTITIES. THE RELEASES OCCURRED ON: FEBRUARY 16, 1989 (7,500 POUNDS OF BENZENE, 2,000 POUNDS OF HYDROGEN SULFIDE, AND 300 POUNDS OF METHYL MERCAPTAN); JULY 1, 1989 (3,300 POUNDS OF BENZENE, AND 3,600 POUNDS OF HYDROGEN SULFIDE); DECEMBER 4, 1989 (60 POUNDS OF BENZENE AND 183 POUNDS OF HYDROGEN SULFIDE); DECEMBER 7, 1989 (50 POUNDS OF BENZENE AND 150 POUNDS OF HYDROGEN SULFIDE); JULY 9, 1990 (400 POUNDS OF BENZEND AND 300 POUNDS OF HYDROGEN SULFIDE); AND AUGUST 9, 1990 (300 POUNDS OF SULFUR DIOXIDE). FOURTEEN OF THE COUNTS WERE LATER DETERMINED NOT TO BE SUSTAINABLE BASED UPON INFORMATION SUPPLIED BY THE RESPONDENT AND ARE DISMISSED IN THE CAFO.