THIS COMPLAINT SERVES AS NOTICE THAT COMPLAINTANT HAS REASON TO BELIEVE THAT MONTANA REFINING COMPANY FAILED TO SUBMIT TIMELY, COMPLETE, AND CORRECT TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORMS AND FAILED TO PREPARE MATERIAL SAFETY DATA SHEETS WITH NOTIFICATION OF EPCRA SECTION 313 CHEMICALS, THE CHEMICALS' CONCENTRATION, AND THE CHEMICAL ABSTRACT SERVICE NUMBERS AS REQUIRED BY SECTION 313 OF EPCRA. THERE ARE TWENTY-THREE (23) COUNTS TO THIS COMPLAINT, WITH A PROPOSED CIVIL PENALTY OF $350,000.