COMPLAINT FILED NOVEMBER 9,1999, AND SETTLEMENT NEGOTIATIONS BEGAN THEREAFTER. SETTLEMENT NEAR, BUT PENDING CONSOLIDATION AND SETTLEMENT OF THIS COMPLAINT WITH 2 SUBSEQUENTLY FILED REGION 5 COMPLAINTS, INCLUDING EPCRA-5-2000-019. THIS CASE WAS CONSOLIDATED AFTER FILING OF THE COMPLAINT, WITH THREE OTHER ADMINISTRATIVE ENFORCEMENT ACTIONS AGAINST OTHER FACILITIES OWNED BY RESPONDENT PIONEER METAL FINISHING CORPORATION. THE FOUR ACTIONS WERE RESOLVED WITH ONE CONSOLIDATED CONSENT AGREEMENT. THE PENALTY AND SEP PRO- JECT IMPOSED AS SET FORTH ABOVE ARE ALL FOUR FACILITIES. THE ENFORCEMENT ACTION AGAINST THE 1717 W. RIVER ROAD NORTH, MINNEAPOLIS, MN, FACILITY WAS FOR RESPONDENT'S FAILURE IN 1995, 1996, AND 1997 TO REPORT TO THE STATE'S EMERGENCY RESPONSE COMMISSION AND TO THE LOCAL FIRE DEPARTMENT, THE EXISTENCE OF TRESHOLD AMOUNTS OF SULFURIC ACID, NITRIC ACID, SODIUM HYDROXIDE, PHOSPHORIC ACID, AND FUEL OIL AT THE FACILITY.