'Complaint filed 9/25/2002, proposing a penalty of $44,250. The complaint alleges: COUNT I - Respondent failed to submit a completed emergency and hazardous chemical inventory form for anhydrous ammonia for calendar year 1999 to the SERC, LEPC, and fire department with jurisdiction over the facility by March 1, 2000. COUNT II - Respondent failed to submit a completed emergency and hazardous chemical inventory form by March 1, 2001, to the SERC, LEPC, and the fire department with jurisdiction over the facility. COUNT III - Respondent failed to submit a completed emergency and hazardous chemical inventory form by March 1, 2001, to the SERC, the LEPC, and the fire department with jurisdiction over the facility. COUNT IV - Respondent failed to immediately report the release to the SERC, as required.