CAFO issued 1/28/2003, assessing a penalty of $25,002. Respondent failed to submit a completed emergency and hazardous chemical inventory form for fuel oil and asphalt petro to the SERC, the LEPC, and fire department with jurisdiction over each of the facilities for calendar years 1999, 2000, and 2001 by March 1 of the year following the calendar year for which a report was required. Respondet did not submit, on or before October 17, 1987, or within three months after Respondent first became subject to OSHA's MSDS requirements, an MSDS or a list including the required information about the fuel oil and asphalt petroleum to the LEPC, the SERC, and the appropriate fire department with jurisdiction over each of the faciliti