Count 1: As of January 23, 2013, Respondent had not submitted to the LEPC and the Allegan Fire District a completed Emergency and Hazardous Chemical Inventory Form including nitric acid for calendar year 2009 under EPCRA Section 312 as required; Count 2: As of January 23, 2013, Respondant had not submitted to the LEPC and the Allegan Fire Department a completed Emergency and Hazardous Chemical Inventory Form including nitric acid by March 1, 2011, for calendar year 2010 as required under Section 312 of EPCRA; Count 3: As of January 23, 2013, Respondent had not submitted to the LEPC a completed Emergency and Hazardous Chemical Inventory Form including nitric acid for calendar year 2011 as required by EPCRA Section 312; Count 4: As of January 23, 2013, Respondent had noot submitted to the Allegan Fire Department a completed Emergency and Hazardous Chemical Inventory Form including nitric acid for calendar year 2011 as required by EPCRA Section 312; Count 5: As of May 9, 2013, Respondent had not submitted to the LEPC a completed Emergency and Hazardous Chemical Inventory Form including nitric acid for the calenday year 2012; and Count 6: As of May 9, 2013, Respondent had not submitted to the Allegan Fire Department a completed Emergency and Hazardous Chemical Inventory Form including nitric acid for calendar year 2012 as required by EPCRA Section 312. Complainant USEPA has allocated the proposed penalties to the various EPCRA countsd of this Complaint as follows: Count 1 - : $1,