THIS AN APO PURSUANT TO SEC 325 OF EPCRA (42 U.S.C. 11045) FOR VIOLATIONS OF SECTION 312 OF EPCRA. THE COMPLAINT WAS ISSUED TO ACCU CHEM CONVERSIONS INC FOR ITS FAILURE TO PROVIDE ANNUAL HAZARDOUS MATERIALS INVENTORIES TO STATE AND LOCAL AGENCIES FOR REPORTING YEARS 1997 AND 1998. THERE ARE TWO FACILITIES INVOLVED IN THIS ACTION. THE PROPOSED PENALTY IS $35,824.