The Administrative complaint is being issued pursuant to Section 325 of the Emergency Planning and Community Right to Know Act (�EPCRA�), 42 U.S.C. Section 11045. The Complaint assesses a penalty of $85,500 for the failure of Pepsi Cola Technical Operations, Inc. (�Respondent�) to submit Emergency and Hazardous Chemical Inventory Forms (�Tier I/Tier II� forms) to the appropriate state and local authorities within the statutorily specified time. At the time of EPA�s first inspection of the Facility on November 29, 2000, approximately 5,150 pounds of ammonia and 19,050 pounds of sodium hydroxide were present at the Facility. A second EPA inspection of the Facility on October 17, 2002 revealed that approximately 5,150 pounds of ammonia and 17,780 pounds of sodium hydroxide were present at the Facility. Ammonia (CAS# 7664-41-7) is an extremely hazardous substance as defined under Section 329(3) of EPCRA, 42 U.S.C. � 11049(3), and 40 C.F.R. � 370.2, with a minimum threshold level for reporting of 500 pounds.Sodium Hydroxide is a �hazardous chemical� as defined under Section 329(5) of EPCRA, 42 U.S.C. � 11049(5), and 40 C.F.R. � 370.2, with a minimum threshold level for reporting of 10,000 pounds. The complaint lists five counts of violations of Section 312, totaling $85,500 in penatlies.