AS PART OF A NATIONAL INITIATIVE, ON MARCH 31, 1997, EPA REGION IX ISSUED A CIVIL COMPLAINT TO DAVIS WIRE CORPORATION FOR SIX VIOLATIONS OF EPCRA SECTION 313 AT THE COMPANY'S HAYWARD, CALIFORNIA FACILITY. THE DAVIS WIRE FACILITY PRODUCES GALVANIZED AND NONGALVANIZED WIRE AND PANELS. IN ITS COMPLAINT, EPA ALLEGES THAT DAVIS WIRE CORPORATION FAILED TO SUBMIT TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORMS FOR CALENDAR YEARS 1991, 1992, AND 1993 FOR AMMONIA AND LEAD AS REQUIRED BY SECTION 313 OF EPCRA AND IMPLEMENTING REGULATIONS.