DURING THE PERIOD FROM ABOUT 3:30 PM TO ABOUT 5:18 PM, ON 11/24/91, WHEN RESPONDENT WAS THE OWNER OR OPERATOR OF THE FACILITY, THERE WAS A RELEASE FROM THE FACILITY OF GREATER THAN ONE THOUSAND POUNDS OF SULFUR DIOXIDE, A QUANTITY GREATER THAT THE REPORTABLE QUANTITY OF ONE POUND. RESPONDENT DID NOT IMMEDIATELY PROVIDE NOTICE TO THE EMERGENCY COORDINATOR OF THE SALT LAKE CITY LOCAL EMERGENCY PLANNING COMMITTEE AFTER THE RELEASE; INSTEAD RESPONDENT NOTIFIED THE SALT LAKE CITY LOCAL EMERGENCY PLANNING COMMITTEE 25 MINUTES AFTER THE RELEASE BEGAN. THE TWO COUNTS IN THIS COMPLAINT SEEK PROPOSED CIVIL PENALTIES IN THE AMOUNT OF $33,250.