THIS COMPLAINT AND NOTICE OF OPPORTUNITY FOR HEARING IS ISSUED AGAINST NEPHI RUBBER PRODUCTS CORPORATION FOR FAILURE TO SUBMIT MSDS FOR CARBON BLACK TO SERC AND LEPC (COUNTS I AND II); FAILURE TO SUBMIT INVENTORY FORMS FOR CARBON BLACK TO SERC AND LEPC (COUNTS III AND IV); FAILURE TO SUBMIT MSDS FOR TOLUENE TO SERC AND LEPC (COUNTS V AND VI); FAILURE TO SUBMIT INVENTORY FORMS FOR TOLUENE TO SERC AND LEPC (COUNTS VII AND VIII); FAILURE TO SUBMIT MSDS FOR CADMIUM STEARATE TO SERC AND LEPC (COUNTS IX AND X); FAILURE TO SUBMIT INVENTORY FORMS FOR CADMIUM STEARATE TO SERC AND LEPC (COUNTS XI AND XII); FAILURE TO SUBMIT MSDS FOR NITROGEN TO SERC AND LEPC (COUNTS XIII AND XIV); AND FAILURE TO SUBMIT INVENTORY FORMS FOR NITROGEN TO SERC AND LEPC (COUNTS XV AND XVI). THE TOTAL PROPOSED CIVIL PENALTY FOR THE 16 COUNTS IS $49,920.