THIS IS AN EPCRA ADMINISTRATIVE COMPLAINT FOR ALLEGED VIOLATIONS OF SEC. 313 OF EPCRA. THE COMPLAINT CONTAINS 81 COUNTS, MOST OF WHICH RELATE TO RHONE'S ALLEGED FAILURE TO FILE FORM R'S AND/OR FAILURE TO PROPERLY MAINTAIN THE RECORDS REQUIRED BY EPCRA. THE AGENCY PROPOSES A PENALTY OF $638,400 FOR THE VIOLATIONS.