FACILITY WAS INSPECTED ON NOV. 17, 1999. AT THE TIME OF THE INSPECTION EPA URGED THE COMPANY'S MANAGEMENT TO RE- VIEW THEIR INVENTORY AND SUBMIT REQUIRED PAPERWORK THAT VERIFIED THAT THE COMPANY WAS SUBJECT TO THE REGULATORY REQUIREMENTS OF EPCRA SECT/313. EPA FURTHER SUGGESTED TO MGMT TO REVIEW THE PROCESSING OF ITS ETHYLENE GLYCOL TANK AND SUBMITT THE APPROPRIATE 1998 FORM R TO EPA AND THE CORRESPONDING STATE OFFICE. NO FORM R HAS YET BEEN FILED. * 02/21/01 - COMPLAINT ISSUED * 08/30/01 - CA/FO ISSUED. THE PROPOSED PENALTY WAS $5,000 AND A FINAL PENALTY OF $3,000 WAS ALLOWED FOR ATTITUDE AND OTHER FACTORS AS JUSTICE MAY REQUIRE. *